In Garza v. Tex. Alcoholic Beverage Comm'n, 89 S.W.3d 1, 5-6 (Tex. 2002), because "nothing in the record showed that the district court rendered judgment orally in open court, or otherwise publicly announced its decision, before the ten day deadline expired," the supreme court held that the trial court's judgment signed outside the ten-day period was untimely. Id. at 5-7.
The supreme court in Garza expressly noted, however, that "regardless of how rendition occurs, section 11.67 does not prevent a district court from performing the ministerial act of memorializing a timely rendition in a signed judgment after the ten day period has passed." Id. at 2.