Word of Faith World Outreach Center Church, Inc. v. Oechsner

In Word of Faith World Outreach Center Church, Inc. v. Oechsner, 669 S.W.2d 364 (Tex.App.1984), the case was tried to the bench and the parties stipulated to the case being decided on the appellee's exhibits based on their agreement that there was no dispute of facts. The parties then submitted their trial briefs to the court, which prompted the appellant to seek to reopen the case. The appellant argued that the appellee's brief introduced a fact dispute which affected the appellant's stipulation to the matter being tried on the appellee's exhibits. The trial court denied the request to reopen the case for additional evidence. The Texas Court of Appeals noted that the trial court's discretion should be liberally exercised in the interest of permitting both sides to fully develop the case in the interest of justice. Id. The court went so far as to state that the trial court has a duty to reopen the case where the proffered additional evidence is decisive and reception of it would not cause undue delay or do an injustice. The appellate court found that each of the factors had been satisfied and that the trial court accordingly abused its discretion. Id.