J. H. Tigner v. First National Bank of Angleton

Summary

The Texas Supreme Court reversed both the trial court and the Court of Civil Appeals, holding that the existence of a statutory landlord's lien on the cotton could not be determined on summary judgment because material facts about crop type and value were unresolved; the case was remanded for further fact development. Justices Griffin dissented, arguing that the lien attaches at contract formation and should be enforced, while Justice Garwood concurred with the majority's construction of the statute.