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Dispute began after the couple moved out
A Texas landlord who retained a couple’s $2,600 security deposit and sued them for additional money after they moved out has lost most of her appeal against a judgment in the tenants’ favour. In a memorandum opinion dated October 15, 2026, the Texas Fourteenth Court of Appeals upheld the lower court’s decision in Yunan Angelina Zhou v. 2, where the case was heard in a trial without a jury.
Because there was no evidence, the judges also clarified that the trial court had not simply dismissed Zhou’s claims. Because Zhou could not demonstrate from the available record that the trial court’s findings were legally or factually incorrect, the appeals court rejected her challenges to the underlying claims and the statutory liability finding. Adrienne Rawlings and Corey Rawlings, while correcting the calculation of damages and prejudgment interest. The dispute centred on alleged repair, cleaning, rekeying and painting costs, as well as whether the landlord had wrongfully withheld the deposit under Texas law. The ruling leaves the tenants’ main victory intact. When the couple did not pay the additional amount, Zhou filed a lawsuit in justice court, alleging breach of contract and fraud. The Rawlingses responded with counterclaims, seeking statutory damages and other relief over the landlord’s retention of their security deposit. The dispute eventually reached Harris County’s County Civil Court at Law No. The court ruled against Zhou on her claims and awarded the Rawlingses damages under Texas’s security-deposit law, along with prejudgment interest, attorney’s fees, costs and post-judgment interest. Zhou then appealed the judgment to the Texas Fourteenth Court of Appeals. Rather, it had found that she failed to establish her claims by a preponderance of the evidence.
Why the security deposit became central to the case
Because the record was incomplete, however, the appellate court concluded that it could not overturn the trial court’s decision on that basis. Zhou challenged the statutory award, arguing that the Rawlingses had not provided a forwarding address as required by Texas law. She maintained that this failure meant they were not entitled to the damages awarded. Neither party had requested a court reporter to record the trial proceedings, leaving the appeals court without a transcript showing what evidence had been presented. The absence of a trial transcript proved important to the outcome. Zhou argued that the evidence did not support the rejection of her breach-of-contract and fraud claims, or the statutory damages awarded to the Rawlingses. The appeals court explained that a party challenging the sufficiency of evidence must provide an adequate appellate record. Without a transcript, the court generally presumes that the missing portions support the trial court’s judgment.