In Dunn v. County of Dallas, 794 S.W.2d 560 (Tex. App.-Dallas 1990, no writ), the Court found that a letter signed by the trial judge, requesting the reassignment of a case because of the trial judge's compulsion to recuse himself, constituted a valid recusal order. Id. at 562.
Also, the parties and the administrative court judge received copies of the letter. Id. at 561.
The Court reasoned the letter notified the parties and the presiding administrative judge of the judge's decision to recuse himself and found the letter constituted a clear and unequivocal act of the court. Id. In Dunn v. County of Dallas, the trial judge wrote, signed, and sent a letter to the administrative judge of the judicial district specifically addressing the subject of recusal.
The Dunn court construed the letter as an order of recusal by the trial judge, and held a subsequent summary judgment granted by the same judge to be void pursuant to the provisions of Tex. Sup. Ct. Rule 18a(c). Id. at 563.