Tara S. Brighton F/K/A Sybil B. Koss v. Gregory Koss

Generally, a postjudgment motion is subsumed by a subsequent judgment that grants all of the relief requested in the motion. Wilkins v. Methodist Health Care Sys., 160 S.W.3d 559, 563-64 (Tex.2005). When subsumed by the subsequent judgment, the motion does not extend the appellate deadlines after the subsequent judgment. Id. at 562. But when a subsequent judgment does not grant all requested relief, the motion remains as a viable complaint about the subsequent judgment and extends the appellate deadlines after that judgment. Id.

This case involves the latter circumstance — a second judgment…