Yunan Angelina Zhou kept Adrienne and Corey Rawlings’s $2,600 deposit and sued them for repairs, cleaning, rekeying and paint. They countersued. On 15 October 2026 Texas’s Fourteenth Court of Appeals left standing, with math fixes, the judgment from Harris County Civil Court at Law No. 2. The docket is 14-25-01119-CV. The landlord lost her contract and fraud claims. The tenants keep statutory damages, fees and interest, recast.

Texas Property Code §92.104 lets a landlord deduct what a tenant actually owes, not ordinary wear, and generally requires a written itemised list. §92.109: a bad-faith withholding can mean $100, three times the sum wrongly kept, and lawyers. The trial court gave the Rawlingses both the deposit and $7,800 (three times $2,600). The appeals court said that counted the deposit twice. Total damages stay $7,800. Prejudgment interest fell from $3,019.36 to $158.

Zhou said the couple left no forwarding address, so they should not have the statutory award. The appeals court could not test that: nobody asked for a court reporter. Without a transcript, the missing record is presumed to support the trial findings. The same gap blocked her attack on attorney fees. That does not mean every landlord always loses. It means an appeal on the evidence is nearly dead without a full record.

Zhou started in justice court. The case rose to County Civil Court at Law No. 2, no jury. She lost there. The appeal gave her the arithmetic only. The Times of India summarised the memorandum opinion. Justia lists the decision among those filed 15 October.

This is not a new statute. It is the deposit rule applied. The alleged repairs were not proved, at trial, to the required standard. Without a transcript the Fourteenth Court did not reopen the facts.

For tenants, the main win stands. For landlords: a written list, wear versus damage, and a reporter if you want an evidence appeal.

Image: i_am_jim, 1910 Harris County Courthouse, Houston, 20 January 2013, CC BY-SA 3.0, Wikimedia Commons. A historic district building, not Civil Court at Law No. 2.

Sources consulted: Texas landlord kept a couple’s $2,600 security deposit and sued them — The Times of India; Yunan Angelina Zhou v. Adrienne Rawlings and Corey Rawlings, 14-25-01119-CV — Texas Fourteenth Court of Appeals (Justia).