In Aranda v. Dist. Clerk, 207 S.W.3d 785, 786 (Tex. Crim. App. 2006), the court held that a person found to be a vexatious litigant under that chapter is not prohibited from filing an application for an article 11.07 writ of habeas corpus because: (1) chapter 11 only prohibits the filing of new civil actions and (2) an application for habeas relief under article 11.07 is not a civil action. Id. The court referenced Rieck and noted that "we have said that when a person is confined for violating a criminal statute and files an application for a writ of habeas corpus challenging his confinement, the proceeding is criminal, not civil, in nature." Id. Thus, under Texas law, an application for habeas relief under article 11.07 is not a civil action that an inmate may be prohibited from filing if that inmate has been declared a vexatious litigant under section 11.054.