Richard Gunn, Petitioner v. Calvin J. Cavanaugh, Respondents

Summary

The Texas Supreme Court affirmed the Court of Civil Appeals, holding that a non‑cited natural father cannot seek a writ of error to challenge an adoption decree and must instead pursue a bill of review. The majority relied on Texas statutes and procedural rules limiting writs of error to parties of record. Justice Steakley dissented, arguing that the father’s interest appears on the record and that due‑process requires allowing a writ of error.