Bell v. Tex. Dep't of Criminal Justice-Institutional Div
In Bell v. Tex. Dep't of Criminal Justice-Institutional Div., 962 S.W.2d 156 (Tex. App.--Houston 14th Dist. 1998, pet. denied), the Court held that dismissal of Bell's suit was proper because his "affidavit relating to previous filings was inadequate." 962 S.W.2d at 158.
There, the trial court dismissed the suit as frivolous. Id.
On appeal, the court held that Bell's affidavit was insufficient to meet the requirements of section 14.004 because he did not state the operative facts or the parties involved in the previously-filed lawsuits. Id.
Without the required information, the trial court could not determine if his claim was "substantially similar to a previous claim," so dismissal was appropriate. Id.