Manufactured Housing Unit Foreclosure Process
This chapter addresses the foreclosure process involving a manufactured home, also known as a mobile home or, more accurately, a manufactured housing unit (MHU). The Texas Department of Housing and Community Affairs (TDHCA), through its Manufactured Housing Division, regulates the manufactured housing industry in Texas. It administers the TDHCA Manufactured Housing Rules and Texas Manufactured Housing Standards Act (Texas Occupations Code chapter 1201) and acts as the U.S. Department of Housing and Urban Development’s (HUD’s) state supervisory agent to administer certain aspects of the National Manufactured Housing Construction and Safety Standards Act of 1974.
If a manufactured home is personal property, chapter 9, subchapter F, sections 9.601 through 9.628, of the Texas Business and Commerce Code governs the foreclosure of a security interest in the manufactured home. Even if the manufactured home is personal property, if the manufacturer, model, year, and serial number is specifically described in the deed of trust to be foreclosed, Tex. Bus. & Com. Code § 9.604 provides the manufactured home may be nonjudicially foreclosed under chapter 51 of the Texas Property Code. Often an MHU is converted to real property under the procedures found in section 2.001 of the Texas Property Code, and if the MHU has been properly converted to real property, it can be foreclosed in the same manner as real property is judicially or nonjudicially foreclosed. Because MHUs are often financed in accordance with chapter 347 of the Texas Finance Code, it must be consulted with reference to insurance and taxes, allowable fees and charges, actions on default, possessory liens, unpaid rent, and the rights, duties, liabilities, and penalties that may be imposed on the creditor or the residential mortgage loan originator.
§ 29.2Definition of Manufactured Home
Section 1201.003(12)(A) of the Texas Occupations Code defines a manufactured home as a structure constructed on or after June 15, 1976, according to the rules of HUD; built on a permanent chassis; designed for use as a dwelling with or without a permanent foundation when the structure is connected to the required utilities; transportable in one or more sections; and in the traveling mode, at least eight body feet in width or at least forty body feet in length or, when erected on site, at least 320 square feet. Tex. Occ. Code § 1201.003(12)(A).
A manufactured home also includes the plumbing, heating, air conditioning, and electrical systems of the home. Tex. Occ. Code § 1201.003(12)(B).
Section 347.002(a)(5) of the Texas Finance Code further defines a manufactured home as including any furniture, appliances, drapes, carpets, wall coverings, or other items that are attached to or contained in the structure and that are included in the cash price and sold in conjunction with the structure. Tex. Fin. Code § 347.002(a)(5).
“Consumer,” as used in a manufactured home credit transaction, is broadly defined as “a person to whom credit is extended in a credit transaction.” Tex. Fin. Code § 347.002(a)(1). This definition of consumer is broader than a consumer in other contexts, for example, persons acquiring goods or services for “personal, family, or household purposes” (see, for example, Texas Business and Commerce Code section 9.102(a)(23)), and thus also encompasses financing a purchase of a manufactured home for use at a construction site or for use as a place of business. In this latter context, the debtor is a consumer protected under chapter 347 of the Finance Code, but the manufactured home is not a “consumer-goods transaction” under chapter 9 of the Business and Commerce Code. See Tex. Bus. & Com. Code § 9.102(a)(24). For chapter 347 of the Finance Code to apply, there must be a “retail purchase” and a purchase money lien. See Tex. Fin. Code § 347.002(a)(1), (a)(3)(A).
§ 29.4Procedure to Perfect Lien on MHU as Real Property
If a new MHU is sold with the intent of it being designated as real property, a Manufacturer’s Certificate of Origin (MCO), together with an Application for Statement of Ownership and Location (SOL), must be submitted to TDHCA with the appropriate application fee to convert the MHU to real property. The SOL must identify the lienholder and specifically describe the manufacturer, model, year, and serial or HUD ID number of the MHU. Additionally, a moving permit issued by the Texas Department of Transportation (TXDOT) must be submitted to TDHCA if the home was moved onto the real property as part of the sale. See Statement of Ownership and Location (SOL) Application Instructions, Texas Department of Housing and Community Affairs, Manufactured Housing Division, last revised January 16, 2021, www.tdhca.state.tx.us/mh/docs/1037-applysol.pdf(hereinafter SOL Instructions).
If a used manufactured home is sold with the intent of it being designated as real property, an SOL application must be submitted to TDHCA with the appropriate application fee. If an existing mortgage lien encumbers the manufactured home, TDHCA Form B, Release of Lien or Repossession, must also be submitted, which releases any prior personal property lien, or documentation must be submitted showing the lien has been paid in full or has been released. In addition, TDHCA Form 1076, Statement from Tax Assessor-Collector, or a “Paid in Full” tax receipt must be submitted showing no personal property taxes are due on the home. Also, a TXDOT moving permit must be submitted to TDHCA if the home was moved onto the real property as part of the sale. See SOL Instructions.
Neither the owner of record of the manufactured home nor the lienholder may convert the designation of the home from personal property to real property or from real property to personal property without the consent of both parties. See section 29.12 below for a discussion of converting an MHU from real property to personal property.
§ 29.5Procedure to Perfect Lien on MHU as Personal Property
If a new manufactured home is sold with the intent of it being designated as personal property, the MCO together with an SOL application must be submitted to TDHCA with the appropriate application fee. Additionally, a TXDOT moving permit must be submitted to TDHCA. See SOL Instructions.
Similarly, if a used manufactured home is sold with the intent of it being designated as personal property, an SOL application must be submitted to TDHCA with the appropriate application fee. If a mortgage lien exists, TDHCA Form B, Release of Lien or Repossession, must also be submitted, which releases any prior personal property lien, or documentation must be submitted showing the lien has been paid in full or has been released. In addition, TDHCA Form 1076, Statement from Tax Assessor-Collector, or a “Paid in Full” tax receipt must be submitted showing no personal property taxes are due on the home. Also, if the home was moved, a TXDOT moving permit must be submitted to TDHCA. See SOL Instructions.
Neither the owner of record of the manufactured home nor the lienholder may convert the designation of the home from personal property to real property or from real property to personal property without the consent of both parties. See section 29.11 below for a discussion of converting an MHU from personal property to real property.
If an MHU is personal property but the secured transaction includes real property on which the MHU is affixed or is to be affixed, the MHU may be foreclosed as part of the real property foreclosure proceeding so long as the MHU is adequately described in the security instruments (manufacturer, model, year, and serial number). See Tex. Bus. & Com. Code § 9.604.
An action to commence repossession, foreclosure, or acceleration of the loan agreement involving a manufactured home must comply with the regulations of the Office of the Comptroller of the Currency relating to the disclosure required for repossession, foreclosure, or acceleration except in extreme circumstances, including abandonment or voluntary surrender of the manufactured home. Tex. Fin. Code § 347.356. It should be noted that the notice provisions in the Texas Business and Commerce Code still apply even if the home is personal property and is abandoned or voluntarily repossessed. All Valley Acceptance Co. v. Durfey, 800 S.W.2d 672 (Tex. App.—Austin 1990, writ denied) (holding that abandonment or voluntary repossession does not constitute waiver of debtor’s right to notice of repossession and intent to sell as required by Texas Business and Commerce Code).
§ 29.7Acceleration and Computation of Charges
Only if the consumer is in default of the performance of an obligation under the credit transaction may a creditor accelerate the maturity of all or a part of the amount owed under the loan agreement for the purchase of a manufactured home. Tex. Fin. Code § 347.352. In computing the amount owed, the creditor must grant to the consumer a refund of the finance charge computed under Finance Code section 347.155. Tex. Fin. Code § 347.353. If the maturity of a debt is accelerated, interest accrues on the amount owed under the credit transaction, including expenses for reasonable attorney’s fees, court costs, and disbursements, and on the charge and collection of actual and reasonable out-of-pocket expenses incurred in connection with repossession or foreclosure of the manufactured home that secures the payment of the credit transaction, including the costs of storing, reconditioning, and reselling the manufactured home, subject to the standards of good faith and commercial reasonableness set by the Texas Business and Commerce Code. Tex. Fin. Code §§ 347.354, 347.307.
If a consumer is in default, the creditor may repossess the manufactured home if it is personal property. Tex. Fin. Code § 347.355(a). A lien on a manufactured home is defined as—
(A)a security interest created by a lease, conditional sales contract, deed of trust, chattel mortgage, trust receipt, reservation of title, or other security agreement if an interest other than an absolute title is sought to be held or given in a manufactured home; or
(B)a lien on a manufactured home created by the constitution or a statute.
Tex. Occ. Code § 1201.201(6). A security interest in a manufactured home is defined as an interest in the home as personal property or a fixture which secures payment or performance of an obligation. Tex. Occ. Code § 1201.201(10); Tex. Bus. & Com. Code § 1.201(b)(35).
A security interest in a manufactured home will be recorded on the document of title or statement of ownership. As defined in Texas Occupations Code section 1201.201, a document of title means a written instrument issued by TDHCA before September 1, 2003, that provides the information contained in the SOL form under section 1201.205 as that section existed before September 1, 2003. Beginning September 1, 2003, a document of title is considered to be a statement of ownership and may be exchanged for a statement of ownership as provided by Occupations Code section 1201.214. Tex. Occ. Code § 1201.201(2).
A security interest in a manufactured home is only perfected by filing with TDHCA the notice of lien on a form provided by the TDHCA. The TDHCA is the party of record and discloses on its website the date of each lien filing. A lien recorded with the TDHCA has priority, according to the chronological order of recordation, over another lien or claim against the manufactured home. Tex. Occ. Code § 1201.219(b).
If the manufactured home has been affixed to real property, the creditor, after notice, may remove the manufactured home from the real property in accordance with the applicable provisions of the Business and Commerce Code as if it were personal property. Tex. Fin. Code § 347.355(b).
§ 29.9Foreclosure of MHU as Real Property
Texas Occupations Code chapter 1201 governs the issuance of a statement of ownership for manufactured homes. In completing an application for a statement of ownership, an owner of a manufactured home must indicate whether the owner elects to treat the home as personal property or real property. Tex. Occ. Code § 1201.2055(a). An owner may elect to treat a manufactured home as real property only if the home is attached to—
(1)real property that is owned by the owner of the home; or
(2)land leased to the owner of the home under a long-term lease, as defined by TDHCA rule.
Tex. Occ. Code § 1201.2055(a). If an owner elects to treat a manufactured home as real property, TDHCA must issue to the owner a copy of the statement of ownership that on its face reflects that the owner has elected to treat the manufactured home as real property at the location listed on the statement. Tex. Occ. Code § 1201.2055(d). A real property election for a manufactured home is not considered to be perfected until a copy of the statement of ownership has been filed within sixty days of issuance in the real property records of the county in which the home is located and TDHCA and the chief appraiser of the appraisal district where the home is located have been notified of the filing. Tex. Occ. Code § 1201.2055(d), (e). After the real property election is perfected, the manufactured home is considered to be real property for all purposes. Tex. Occ. Code § 1201.2055(g).
To determine whether or not the owner of the manufactured home has elected to treat the home as real property or personal property, the first step is to access the TDHCA website, www.tdhca.state.tx.us/mh/index.htm, and select the “Search Our Database” link under the “Manufactured Housing Division” tab. Then, select “View home ownership records” to access the certificate of detail for the manufactured home made subject of the real property foreclosure. If the real property election has been perfected on the home, the following statement will appear in bold at the top of the certificate of detail:
The real property election for this home has been perfected.
Once the manufactured home has been converted to real property, as evidenced by the statement of ownership filed in the real property records or confirmed by TDHCA, foreclosure of the real property includes the manufactured home—without the necessity of the MHU being specifically described in the security instrument.
§ 29.10Foreclosure on MHU as Personal Property
If the real property election has not been perfected for a manufactured home, it is possible to conduct a foreclosure on the real property and home at the same time. But the deed of trust on the real property must specifically describe the MHU before the secured party can concurrently foreclose both the personal property and the real property under the deed of trust, in accordance with Tex. Prop. Code ch. 51, Tex. Bus. & Com. Code § 9.604(a)(2), and the terms of the deed of trust.
If the manufactured home is personal property but not described in the security agreement, after default, a secured party may reduce its claim to judgment on the note or enforce the claim or security interest by any available judicial procedure. See Tex. Bus. & Com. Code § 9.601(a)(1). These rights may be modified by agreement of the parties except as otherwise provided in Business and Commerce Code sections 9.602 and 9.624. See Tex. Bus. & Com. Code §§ 9.602, 9.624. After default, a secured party may repossess the MHU, if repossession is done without breach of the peace or by judicial process. Tex. Bus. & Com. Code § 9.609(a), (b). If the secured party chooses self-help repossession, it runs the risk that the repossession may breach the peace, which could result in the secured party being held liable in tort. MBank El Paso, N.A. v. Sanchez, 836 S.W.2d 151, 152 (Tex. 1992). A duty is imposed on secured creditors pursuing a nonjudicial repossession to take precautions for public safety, and a secured creditor is prohibited from delegating this duty to an independent contractor. Sanchez, 836 S.W.2d at 153.
§ 29.11Conversion of MHU from Personal Property to Real Property
After a manufactured home is acquired by self-help repossession, an execution or judicial foreclosure sale by the sheriff or constable after a judgment and order of sale is obtained, or nonjudicial foreclosure sale, the purchaser may elect to convert the manufactured home from personal property to real property. In order for a home to be converted from personal property to real property, each lien on the home must be released by the lienholder or each lienholder must give written consent of the conversion, which must be filed with TDHCA. Tex. Occ. Code § 1201.2075(a). The conversion may not be completed until all lienholders release or give written consent to the conversion; however, TDHCA can issue a statement of ownership to a licensed title insurance company that commits to issuing a title commitment policy covering all prior liens on a loan that the title company closes or to a federally insured financial institution or licensed attorney who has obtained a title insurance policy covering all prior liens on the MHU. Tex. Occ. Code § 1201.2075(b).
The purchaser must complete an SOL application, which may be filled out and printed from the TDHCA website, www.tdhca.state.tx.us/mh/ownership-location.htm, and submit the required documentation together with the appropriate SOL issuance fee to perfect the conversion from personal property to real property. If a mortgage lien exists, TDHCA Form B, Release of Lien or Repossession, must be completed by the lienholder of record for the release of the personal property lien or documentation submitted identifying the home and verifying that the lien has been paid in full or released. See SOL Instructions. In lieu of a release of lien, conversion may be accomplished by the written consent of each lienholder or a statement by a title company, attorney, or federally insured financial institution that a title commitment covering all prior liens on the home has been issued. Tex. Occ. Code § 1201.2075(b).
Once the application is approved, TDHCA must issue to the owner a copy of the statement of ownership that on its face reflects that the owner has elected to treat the manufactured home as real property at the location listed on the SOL. Tex. Occ. Code § 1201.2055(d). A real property election for a manufactured home is not considered perfected until a copy of the statement of ownership has been filed in the real property records of the county in which the home is located and TDHCA and the chief appraiser of the appraisal district where the home is located have been notified of the filing of a copy of the statement of ownership in the real property records of the county where the MHU is located. Tex. Occ. Code § 1201.2055(e); Tex. Prop. Code § 2.001(b). After the real property election is perfected, the manufactured home is considered to be real property for all purposes. Tex. Occ. Code § 1201.2055(g). When the MHU is converted to real property, the personal property lien is converted to a purchase money lien on the real property by operation of law and exists independently of any existing lien on the real property to which the home is permanently attached. Tex. Prop. Code § 63.003.
§ 29.12Conversion of MHU from Real Property to Personal Property
After a manufactured home encumbered as real property is acquired by a judicial or nonjudicial foreclosure sale, the purchaser may convert the MHU from real property to personal property. The conversion is similar to the conversion of personal property MHU into a real property MHU, but in accordance with Tex. Occ. Code § 1201.2076, which includes getting written consent from the local taxing units. See Tex. Occ. Code § 1201.2076(a). Further, TDHCA also cannot issue a statement of ownership converting the MHU from real property to personal property until the home has been inspected and determined to be habitable. Tex. Occ. Code § 1201.2076(a).
The purchaser must complete an SOL application, which may be filled out and printed from the TDHCA website, www.tdhca.state.tx.us/mh/ownership-location.htm, and submit the required documentation, which includes proof that all real property taxes have been paid, together with the appropriate fee for the habitability inspection and the SOL issuance fee to perfect the conversion from personal property to real property. See SOL Instructions. Once the application is approved and the home passes the habitability inspection, TDHCA issues a statement of ownership to the owner stating that the owner has elected to treat the manufactured home as personal property. The issuance of the statement of ownership is evidence of ownership of the home. Tex. Occ. Code § 1201.2055(c). A lien, charge, or other encumbrance on a home treated as personal property requires filing the appropriate documentation with TDHCA. Tex. Occ. Code § 1201.2055(c).
If a vacant manufactured home is located on real property that was foreclosed, but the security instrument did not encumber the manufactured home, it may be possible to obtain title to the vacant manufactured home through abandonment.
In addition, if a vacant manufactured home is titled in the name of a person or entity other than the owner of the real property on which the MHU is located, the owner may declare the MHU abandoned if the home has been continuously unoccupied for at least four months and any indebtedness secured by the home or related to a lease agreement between the owner of the real property and the owner of the home is considered delinquent. Tex. Occ. Code § 1201.217(a).
Before the MHU can be declared abandoned, the owner of the real property on which the vacant home is located must send a notice of intent to declare the home abandoned to the record owner of the MHU, all lienholders at the addresses listed on the home’s statement of ownership on file with TDHCA, the tax collector for each taxing unit that imposes ad valorem taxes on the real property where the MHU is located, and any intervening owners of liens or equitable interests. Tex. Occ. Code § 1201.217(b). If the person giving such notice knows that a person to whom the notice is being given no longer resides and is no longer receiving mail at a known address, a reasonable effort must be made to locate the person and give the person notice at an address where the person is receiving mail. Tex. Occ. Code § 1201.217(b). Mailing of the notice by certified mail, return receipt requested, postage prepaid, to the persons required to be notified constitutes conclusive proof of the notice requirement to declare the home abandoned. Tex. Occ. Code § 1201.217(b).
On receipt of a notice of intent to declare the MHU abandoned, the record owner, a lienholder, a tax assessor-collector for a taxing unit that imposes ad valorem taxes on the real property on which the home is located, or an intervening owner of a lien or equitable interest may enter the real property where the MHU is located and remove the home. Tex. Occ. Code § 1201.217(c). The real property owner must disclose the location of the home to the record owner, lienholder, tax assessor-collector, or intervening owner of liens or equitable interests in the home and grant the person reasonable access to the home. Tex. Occ. Code § 1201.217(c). A person removing the home is responsible to the real property owner for any damage to the real property resulting from the removal of the home. Tex. Occ. Code § 1201.217(c).
If the manufactured home remains on the real property for at least forty-five days after the date the notice of intent to declare the manufactured home abandoned is postmarked, all liens on the home are extinguished, and the real property owner may then apply for a new statement of ownership listing the real property owner as the owner of the manufactured home. Tex. Occ. Code § 1201.217(d). When applying for a statement of ownership, the real property owner must include an affidavit stating that (1) the person owns the real property where the manufactured home is located and (2) the name of the person to whom title to the home will be transferred is the same name that is listed in the real property or tax records indicating the current ownership of the real property. Tex. Occ. Code § 1201.217(d–1).
Obtaining title to a manufactured home through the abandonment process is not permitted if the person who owns the real property is related to or affiliated with the record owner or has owned an interest in the manufactured home. Tex. Occ. Code § 1201.217(f).
If the manufactured home has been abandoned or voluntarily surrendered by the consumer, Texas Finance Code section 347.402 provides the owner of the real property on which a manufactured home is located with a possessory lien for all rental charges accruing after the fifteenth day after the creditor receives written notice of unpaid land lease charges. See Tex. Fin. Code § 347.402(b)(1). If the MHU is not abandoned or voluntarily surrendered, the possessory lien secures rent after the fifteenth day following (1) the expiration of all notice and grace periods that the creditor is required to give the consumer and (2) the notice of unpaid charges. See Tex. Fin. Code § 347.402(b)(2). The maximum daily rate of rent charges that is secured by the possessory lien is equal to the consumer’s monthly rent divided by thirty. See Tex. Fin. Code § 347.402(c). Chapter 94 of the Texas Property Code contains extensive provisions regulating manufactured home tenancies, including sections 94.051 through 94.109, regarding the provisions in the lease and the relationships and liabilities between the owner of the manufactured home community and its tenants, and sections 94.201 through 94.206, regarding the termination, nonrenewal, and eviction of the tenant. See Tex. Prop. Code ch. 94.
After foreclosure, if the occupant will not voluntarily vacate, a forcible-detainer suit must be filed by the purchaser of the property to recover possession of the manufactured home. If the purchaser prevails in the eviction suit, a writ of possession may be issued, but not before the sixth day after the date on which the judgment for possession is rendered unless a possession bond has been filed and approved under the Texas Rules of Civil Procedure. Otherwise, judgment for possession is granted by default. Tex. Prop. Code § 24.0061(b). The forcible-detainer process is set forth in Texas Property Code chapter 24. See chapter 34 in this manual regarding the eviction process.
§ 29.16Protecting Tenants at Foreclosure Act of 2009
The Protecting Tenants at Foreclosure Act (PTFA), which is title VII, sections 701–704 of the Helping Families Save Their Homes Act of 2009, Pub. L. No. 111-22, 123 Stat. 1632, protected tenants from eviction when a home they occupied was foreclosed. These provisions took effect on May 20, 2009, and expired December 31, 2014. However, on May 24, 2018, Senate Bill 2155 was signed into law, repealing the PTFA’s sunset provision and restoring notification and other requirements related to the eviction of renters in foreclosed properties. See Economic Growth, Regulatory Relief, and Consumer Protection Act, Pub. L. No. 115-174, 132 Stat. 1296 (2018). The PTFA is applicable to a tenant occupying a manufactured home located on the property that is foreclosed and should be reviewed to ensure compliance before eviction.
Further cases relevant to the manufactured housing unit foreclosure process include the following:
1.MBank El Paso, N.A. v. Sanchez, 836 S.W.2d 151, 152 (Tex. 1992) (discussing duty imposed on secured creditors pursuing a nonjudicial repossession to take precautions for public safety and any breach of the peace could result in creditor being held liable in tort).
2.Guerra v. M.H. Equities, Ltd., No. 02-11-00261-CV, 2012 WL 2135596 (Tex. App.—Fort Worth June 14, 2012, no pet.) (mem. op.) (discussing calculation of liquidated damages from balance of a promissory in a foreclosure proceeding involving a manufactured home).
3.Mazon v. Vanderbilt Mortgage & Finance, Inc., No. 03-02-00529-CV, 2006 WL 2083979 (Tex. App.— Austin July 28, 2006, pet. denied) (mem. op.) (discussing whether automatic stay in a bankruptcy proceeding prevented commencement of proceedings to foreclose on a manufactured home).
4.Conseco Finance Servicing Corp. v. Cabrera, 190 S.W.3d 41 (Tex. App.—Amarillo 2005, no pet.) (analyzing procedural requirements for judicial foreclosure of a manufactured home).
5.Conseco Finance Servicing Corp. v. J&J Mobile Homes, Inc., 120 S.W.3d 878 (Tex. App.—Fort Worth 2003, pet. denied) (addressing whether holder of a preexisting security interest in manufactured home which was sold at tax lien foreclosure sale can assert its security interest lien rights to the manufactured home against a bona fide purchaser).
6.W.H.V., Inc. v. Associates Housing Finance, LLC, 43 S.W.3d 83 (Tex. App.—Dallas 2001, pet. denied) (reviewing lien perfection under Texas Manufactured Housing Standards Act).
7.Pokorne Private Capital Group, LLC v. 21st Mortgage Corp., No. 13-06-575-CV, 2008 WL 963296 (Tex. App.—Corpus Christi–Edinburg Apr. 10, 2008, pet. denied) (mem. op.) (discussing whether an application for statement of ownership and location was defective when the application was filed by a previous owner after transfer of home that failed to note an existing lien).
Baird, Morton W., II. “Immobile Home Loans: Mortgage Lending Basics for Manufactured Housing.” In Advanced Real Estate Drafting Course, 2004. Austin: State Bar of Texas, 2004.
Berry, Sarah F. “Manufactured Home Collections: Personal Property or Real Property?” In Collections and Creditors’ Rights Course, 2017. Austin: State Bar of Texas, 2017.
Burkhart, Ann M. “Bringing Manufactured Housing into the Real Estate Finance System.” Pepperdine Law Review 37, no. 2 (2010): 427–57.
Freyermuth, R. Wilson. “Legal and Regulatory Issues in the Creation, Perfection, and Enforcement of Security Interests in Manufactured Homes.” ALI-ABA Course of Study: Commercial and Lending Banking Law (2009): 263–92.
Hale, Kent D., and Steven C. James. “Manufactured Housing Litigation.” In Handling Your First Consumer Law Case Course, 2012. Austin: State Bar of Texas, 2012.
Noriega, Raúl. “Representing Manufactured Homeowners and Renters in Texas.” In Advanced Consumer & Commercial Law Course, 2019. Austin: State Bar of Texas, 2019.