In In re Plaisance, the Fifteenth Court of Appeals recently continued its disagreement over the reach of its jurisdiction. In its June 30, 2026 opinion, a divided Court held that it could hear an interlocutory appeal transferred for docket equalization, but it could not decide a mandamus petition challenging the statutory stay in the same underlying case. The immediate dispute concerned a stay pending interlocutory appeal. The broader issue was whether jurisdiction over an appeal includes authority to address related disputes arising below.

Justice Farris’s majority opinion treated the statutes’ different language as controlling. Chapter 73 gives a court “jurisdiction” over an appeal transferred for docket equalization. But the statute governing the Fifteenth Court’s writ power limits that authority to matters within its “exclusive intermediate appellate jurisdiction.” The majority concluded that equalization jurisdiction, without more, doesn’t include authority to decide a related mandamus petition.

Plaisance didn’t arise on a blank slate. Three months earlier in In re Shelton, the Fifteenth Court considered an interlocutory appeal transferred for docket equalization and a mandamus petition seeking the same relief on the same grounds. Chief Justice Brister’s memorandum opinion dismissed the mandamus proceeding as moot after resolving the appeal. In a concurring opinion, Justice Farris agreed with the result but wrote separately to argue that the court should instead dismiss for lack of writ jurisdiction. In Plaisance, the Shelton concurrence's jurisdictional theory became the Court's holding.

Disagreeing with the majority, Chief Justice Brister’s dissent offered two paths to mandamus jurisdiction. First, the Fifteenth Court’s exclusive jurisdiction includes “any other matter as provided by law,” and Chapter 73 provides jurisdiction over transferred cases. Second, once an appeal is pending, the Court’s appellate authority may permit it to address trial-court orders that threaten its jurisdiction or the effectiveness of its eventual relief, without depending entirely on freestanding original jurisdiction.