North East Independent School District v. Aldridge

In Texas, a trial court's judgment need not expressly dispose of all issues and claims to be final. In North East Independent School District v. Aldridge, 400 S.W.2d 893, 897-98, 9 Tex. Sup. Ct. J. 320 (Tex. 1966), the Court explained: When a judgment, not intrinsically interlocutory in character, is rendered and entered in a case regularly set for a conventional trial on the merits, no order for a separate trial of issues having been entered . . . it will be presumed for appeal purposes that the Court intended to, and did, dispose of all parties legally before it and of all issues made by the pleadings between such parties. Thus, unless the trial court orders a separate trial to resolve a specific dispute, there is a presumption that the trial court's judgment disposed of all of the plaintiff's claims, as well as any cross-actions and counterclaims. Id. at 898. If there is any question about the trial court's intent, "finality 'must be resolved by a determination of the intention of the court as gathered from the language of the decree and the record as a whole, aided on occasion by the conduct of the parties.'" Continental Airlines, Inc. v. Kiefer, 920 S.W.2d 274, 277, 39 Tex. Sup. Ct. J. 468 (Tex. 1996).