Park Place Hosp. v. Estate of Milo

In Park Place Hosp. v. Estate of Milo, 909 S.W.2d 508, 510 (Tex.1995), the Court suggested that the absence of a Mother Hubbard clause indicated that a summary judgment was intended to be interlocutory. There, the trial court granted summary judgment for three of five remaining defendants and later severed the judgment from the case. The Court concluded that the judgment did not become final for purposes of appeal until it was severed, in part based on the omission of a Mother Hubbard clause. But in two other cases we held that the omission of a Mother Hubbard clause did not make a summary judgment interlocutory that otherwise appeared final.