Alicia Moreno v. Liberty Mutual Fire Insurance Company
Alicia Moreno appealed an adverse default judgment by writ of error against Liberty Mutual Fire Insurance Company. The appeal challenged a district court's default judgment that set aside a workers' compensation award previously granted to Moreno by the Workers' Compensation Commission. Moreno raised several points of error, including non-compliance of the citation with Texas Rule of Civil Procedure 16 (regarding endorsement of receipt date/hour), the return's failure to show server authorization, a discrepancy between the service address and the citation's address, and non-compliance with Texas Rule of Civil Procedure 239a concerning notice of default judgment. The appellate court affirmed the default judgment, ruling that minor citation errors were not grounds for reversal, official signatures on returns fulfilled authorization requirements, and address discrepancies did not void service. It also held that Rule 239a violations should be challenged in a bill of review, not a writ of error, and clarified that due process concerns under *Peralta* apply only where a defendant was not served with process.