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Presentation: Trust Distributions in Texas

On May 1, 2025, David F. Johnson presented his paper, “Trust Distributions in Texas,” to the Tarrant County Probate Bar Association. His presentation covered the construction of trusts, various distribution standards...more

Court Affirms A Trial Court’s Order Granting A Receiver’s Request To Sell Real Property

In Estate of Richards, a probate court entered an order appointing a receiver of estate property. No. 11-23-00031-CV, 2024 Tex. App. LEXIS 8626 (Tex. App.—Eastland December 12, 2024, no pet. history)....more

Court Affirmed Probate Order On The Ownership Of Farm Equipment Which Depended On The Location Of The Equipment At The Time Of The...

In Halderman v. Ivy, the decedent’s will stated: “I give, devise and bequeath my 66.977 acres located on FM 1848 in Freestone County, Texas, including all livestock and farm equipment located thereon to my two children . . ....more

Court Reversed Order Setting Aside The Probating Of A Will Where The Evidence Was Insufficient To Support The Order

In In re Estate of Johnson, an administrator and a third party appealed the trial court’s judgment setting aside the probate of the decedent’s will, removing the administrator, and voiding the sale of an estate asset to the...more

Court Dismissed An Appeal From A Probate Court Order Due To A Lack Of Jurisdiction

In In re Estate of Carr, the court of appeals dismissed an appeal from a probate court order due to a lack of jurisdiction. No. 04-23-00287-CV, 2024 Tex. App. LEXIS 7827 (Tex. App.—San Antonio November 6, 2024, no pet....more

Texas Supreme Court Declines The Chance To Rule On Whether There Is A Right To A Jury Trial In A Trust Modification Suit

In In re Troy S. Poe Trust, a co-trustee of a trust filed suit to modify the trust to increase the number of trustees and change the method for trustees to vote on issues as well as other modifications, including, incredibly,...more

Texas Supreme Court Holds That Unsworn Testimony By Attorney Regarding A Lost Will Should Have Been Considered By The Appellate...

In In re Estate of Brown, a charity offered a copy of will to probate. No. 23-0258, 2024 Tex. LEXIS 684 (Tex. August 30, 2024). An attorney offered unsworn testimony regarding the reason for the nonproduction of the original...more

Court Holds That Contingent Remainder Beneficiary Has Standing To Sue Trustee For Breach Of Fiduciary Duty

In In re Est., the court of appeals dealt with whether a contingent beneficiary can file claims against a trustee. No. 02-23-00104-CV, 2024 Tex. App. LEXIS 1878 (Tex. App.—Fort Worth March 14, 2024, no pet.)....more

A Court Affirmed A Construction Of A Will Regarding The Devise Of Real Property

In In re Estate of Martinez, a decedent left a holographic will, and a potential recipient of property under that will offered it for probate and sought a declaration regarding a devise of property. No. 04-22-00708-CV, 2024...more

Court Had Jurisdiction To Determine Claims Involving Non-Probate Assets

In Castaneda v. Chapa, the executrix of an estate sued regarding the decedent changing account designations and a deed to real estate. No.13-22-00537-CV2024 Tex. App. LEXIS 3376 (Tex. App.—Corpus Christi May 16, 2024, no pet....more

Court Reversed A Summary Judgment On Whether A Power Of Attorney Agent For A Settlor Had The Authority To Change The Designation...

In Bass v. Bogle, settlors, husband and wife, created a trust that owned the majority interest in a closely-held business, and they had two children. No. 03-23-00319-CV, 2024 Tex. App. LEXIS 5034 (Tex. App.—Austin July 18,...more

Court Reversed Summary Judgment On Whether A Person Was The Current Trustee And On Certain Modification Claims But Affirmed...

In Crossley v. Crossley, a plaintiff, who was the beneficiary of, or had the power to designate the beneficiary, in two trusts established by his mother, and he filed suit requesting that the court determine whether he or his...more

Texas Supreme Court Reverses Order In Trust Dispute Granting A Constructive Trust

In In re Trust A & Trust C, a beneficiary sued a trustee for breach of fiduciary duty and sought a constructive trust over assets that were transferred out of the trust. 690 S.W.3d 80 (Tex. 2024)....more

Court Affirmed The Removal Of An Executor For Gross Mismanagement

In Gordon v. Gordon, a couple created a revocable trust and named a friend, who provided financial advice, as successor trustee. No. 03-22-00454-CV, 2024 Tex. App. LEXIS 3611 (Tex. App.—Austin May 23, 2024, no pet. history)....more

Court Determined That A Deed Did Not Create A Trust

In Hilderbran v. Tex. SW. Council, Inc., parties donated a ranch via a 1930 deed to trustees for the Boy Scouts. No. 04-22-00736-CV, 2024 Tex. App. LEXIS 4390 (Tex. App.—San Antonio June 26, 2024, no pet. history)....more

Court Affirmed Dismissing Application To Probate Foreign Will

In In re Est. of De Chavez, a party filed an application to probate a Mexican will under Texas Estates Code Section 501.001 where the decedent was domiciled in Texas at the time of her death. No. 08-23-00072-CV, 2024 Tex....more

Court Affirmed Order Admitting Will To Probate Over Undue Influence Allegation And Over An Alleged Subsequent Holographic Codicil...

In Mynard v. Degenhardt, a decedent’s grandson offered a will to probate, and his aunt opposed that admission due to an alleged holographic codicil that allegedly revived a previous will. No. 14-22-00773-CV, 2023 Tex. App....more

Trustee’s Ability To Retain And Compensate Attorneys In Texas - Presentation

David F. Johnson presented his paper titled “Trustee’s Ability To Retain And Compensate Attorneys In Texas” to the Texas State Bar’s 48th Annual Advanced Estate Planning and Probate Course on June 13, 2024, in Houston, Texas....more

Court Construed Holographic Will To Devise Certain Property To A Granddaughter

In In re Estate of Martinez, a son appealed an order finding that his mother’s holographic will devised certain property to his daughter. No. 04-22-00708-CV, 2024 Tex. App. LEXIS 1258 (Tex. App.—San Antonio February 21, 2024,...more

Court Held That Estate Beneficiary Was Not Entitled To Jury Trial On Ratification Of Attorney’s Fees Agreement

In In re Est. of Ellard, a court ratified an executor signing a contingency fee agreement that was over 35% under section 351.152 of the Estates Code. No. 05-22-01149-CV, 2024 Tex. App. LEXIS 483 (Tex. App.—Dallas January 25,...more

Federal Court Dismisses Trust Dispute Due To There Not Being A Justiciable Controversy

In Frank v. Frank, co-trustees filed suit in federal court seeking declarations regarding their authority and potential liabilities. No. 3:22-cv-01757-M, 2023 U.S. Dist. LEXIS 226439 (N.D. Tex. December 20, 2023)....more

Court Affirmed Award Of Damages And Punitive Damages Against A Trustee Due To A Breach Of The Duty To Disclose, Held That A Trust...

In Mendell v. Scott, a decedent had a trust that named him as primary beneficiary, and upon his death, the trust would continue for a niece provided that she did not commit a prohibited act. No. 01-20-00578-CV, 2023 Tex. App....more

Court Held That A Trust Terminated Upon The Primary Beneficiary’s Death And That The Trustee Did Not Have Authority To Accept New...

In Herbig v. Welch, a dispute arose around whether a trust terminated and whether certain transfers were valid. No. 01-22-00080-CV, 2023 Tex. App. LEXIS 4505 (Tex. App.—Houston [1st Dist.] June 27, 2023, no pet.)....more

Court Reverses Summary Judgments On The Alleged Exercise Of A Power Of Appointment, Disclaimer, And The Statute Of Limitations

In In re Estate of Wells, No. 12-23-00066-CV, 2023 Tex. App. LEXIS 8475 (Tex. App.—Tyler November 8, 2023, no pet. history). The testator left a will that created a trust for his wife and descendants, named his wife as the...more

Who Has The Duty To Prepare An Accounting When The Trustee Dies Or Becomes Incapacitated?

Beneficiaries of trust can face a difficult situation when the trustee of their trust either dies or becomes incapacitated. They may have many questions about the trust, such as what assets are in the trust or should be in...more

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