In Esty v. Beal Bank S.S.B., 298 S.W.3d 280 (Tex. App.--Dallas 2009, no pet.), the Dallas Court of Appeals concluded that objections to summary-judgment evidence were not waived simply because the trial court had not ruled on them until after it had signed the final judgment granting or denying the summary judgment. See id. at 295.
The court noted that it was "troubled" by the timing of the rulings and stated that "the better practice" would be for the trial court to disclose, in writing, its rulings on all objections to the summary-judgment evidence at or before the time it signs an order granting or denying summary judgment. Id.
However, because the order ruling on the objections was entered while the trial court retained plenary power and because the rules of civil procedure do not prescribe a period of time in which a court is required to rule on summary-judgment objections, the court could find no reason to disregard the rulings on the objections. Id.; see Tex. R. Civ. P. 166a.