In Henson v. Estate of Crow, 734 S.W.2d 648 (Tex. 1987), the defendant died while the suit was pending and a notice of death was filed. Id. at 649.
An amended petition named the estate as the defendant, and the attorney who had represented the deceased while alive filed an answer on behalf of the estate. Id.
The Supreme Court affirmed the summary judgment because no personal representative made an appearance, and there was nothing in the record to show that the attorney who filed the answer for the estate was representing the personal representative of the estate. Id.