This question has been addressed in 1 Texas court opinion:
COA01 — February 3, 2026
In Bustamante v. Bustamante, the First Court of Appeals addressed whether a trial court's order granting a bill of review—which vacated a prior 2023 judgment without resolving the underlying merits—could be immediately appealed. The court analyzed Texas jurisdictional principles, noting that appellate review is generally limited to final judgments unless a statute specifically authorizes an interlocutory appeal. Because the order only 're-opened' the litigation and did not fall under the authorized list of interlocutory appeals in the Texas Civil Practice and Remedies Code, the court held it lacked jurisdiction and dismissed the appeal.
Litigation Takeaway
“The granting of a bill of review is a non-appealable interlocutory order if the underlying merits remain unresolved. Practitioners must proceed through a second trial on the merits before they can challenge the propriety of the bill of review on appeal.”