Abarca v. Roadstar Corp. of Am
In Abarca v. Roadstar Corp. of Am., 647 S.W.2d 327, 327-28 (Tex. App.--Corpus Christi 1982, no writ), the court held that a letter to the parties, setting forth the trial court's decision and requesting that a judgment be prepared, "was the rendering of the judgment in this case." Id. at 328.
Because the judge who wrote the letter died before signing the prepared judgment, his successor in office signed it instead. Id.
The court of appeals determined that the new trial judge could properly sign the judgment based on the findings expressed in his predecessor's letter, as the letter was the actual rendition of judgment and the successor's "act in signing the formal document called the judgment merely recorded this rendition." Id.
In reaching this conclusion, the court emphasized the fact that the letter to the parties "certainly qualifies as a memorandum, and it was filed with the clerk." Id.