law-appeal-must-challenge-all-bases-for-judgment
09‑0314 WILLIAM CRAIG RILEY v. GARY J. COHEN; from Travis County; 3rd district (03-08-00285-
CV, ___ SW3d ___, 02‑19‑09)(sanctions appeal, appellate procedure failure to challenge all bases
for judgment, pro se litigants). Riley invokes the line of cases holding that rule 13's particularity
requirement is mandatory and that noncompliance constitutes harm and reversible error. (1)
However, the judgment, on its face, also purports to be based on chapter 9 of the civil practice and
remedies code. Riley does not challenge this alternative ground that could support the judgment.
(2) Because Riley has waived any complaint with this ground for the judgment, we affirm. (3) See, e.
g., Texas Dep't of Human Res. v. Orr, 730 S.W.2d 435, 436 (Tex. App.--Austin 1987, no writ)
("Should a judgment rest upon more than one ground, the party aggrieved by the judgment must
assign error as to each such ground or risk having the judgment affirmed on the ground to which
no error was assigned."); see also In Re Hansen, No. 05-06-00585-CV, 2007 Tex. App. LEXIS
2115, at *1-3 (Tex. App.--Dallas Mar. 20, 2007, no pet.) (mem. op.) (where sanctions ordered
under rule 13 and chapter 10, and appellant only complained of order under rule 13, any error was
harmless because "the unchallenged independent ground fully supports the complained-of ruling").