Caldwell v. Callender Lake Property Owners Improvement Assoc

Caldwell v. Callender Lake Property Owners Improvement Assoc., 888 S.W.2d 903 (Tex. App.--Texarkana 1994, writ denied) concerned a challenge by two property owners to an increase in maintenance fees charged by the property owners association. After losing in the trial court, the property owners sought to have the trial court's judgment overturned on the ground that the trial court never should have adjudicated the case they brought before it because all of the other property owners were indispensable parties. Caldwell, 888 S.W.2d at 907. The appellants argued that the trial court's judgment would have res judicata effect on the other property owners. Id. The court of appeals rejected this argument because Tex. Civ. Prac. & Rem. Code section 37.006(a) of the civil practice and remedies code specifically provides that a declaratory judgment does not prejudice the rights of any person not a party to the proceeding. Id. (citing TEX. CIV. PRAC. & REM. CODE 37.006(a)).