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Presentation: Fiduciary Litigation Update 2023-2024

At the Texas Bankers Association Annual Convention on April 24, 2025, David F. Johnson presented his paper “Fiduciary Litigation Update 2023-2024.” David addressed key topics, including the right to a jury trial in trust...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

Court Holds That Party Waived Appeal By Not Timely Appealing An Order Admitting A Will To Probate

In In re Est. of Wheatfall, a trial court entered an order admitting a will to probate and denying a will contestant’s claims. No. 01-22-00920-CV, 2024 Tex. App. LEXIS 5503 (Tex. App.—Houston [1st Dist.] August 1, 2024, no...more

Court Reversed A Judgment Based On A No-Contest Clause Because After Nonsuiting The Will Contest Pleading, The Trial Court Did Not...

In In re In the Estate of Wegenhoft, an applicant filed an application to probate a will, which contained a no-contest clause. No. 14-23-00350-CV, 2024 Tex. App. LEXIS 5352 (Tex. App.—Houston [14th Dist.] July 30, 2024, no...more

Court Holds That Mental Competence Claims Regarding The Execution Of Documents Containing Arbitration Clauses Should Be Determined...

In In re Est. of Moncrief, certain parties alleged that the decedent was mentally incompetent, was unduly influenced, and was defrauded into executing certain documents that contained arbitration clauses. 699 S.W.3d 315 (Tex....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

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 Granted Motion To Abate A Suit To Remove A Trustee In District Court Because A First Filed Suit In A County Court At Law Had...

In In re Kelly, a former executor and the trustee of a testamentary trust initiated a probate proceeding in a county court at law. No. 11-24-00066-CV, 2024 Tex. App. LEXIS 3735 (Tex. App.—Eastland May 30, 2024, original...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

Texas Supreme Court To Review Joinder Issue In A Trust Dispute

In In re Tr. A & Tr. C, Established Under Bernard L. & Jeannette Fenenbock Living Tr. Agreement, Dated Mar. 12, 2008, a co-trustee of a family trust transferred stock from the trust to her personal trust and then sold the...more

Court Holds That An Order Was Not Final For Appeal Where There Was Still An Issue Of Intestancy Remaining To Be Determined

In Estate of Long, the plaintiff sued trustees and alleged that she was the only child of the decedent and asserted a cause of action for a will contest and a cause of action for a declaratory judgment action in which she...more

Court Granted Mandamus Relief To Order District Court To Abate Trust Dispute Due To Earlier Filed Suit In Probate Court

In In re McGowan, a dispute arose regarding whether certain interests in real property were funded into a trust or whether the decedent still had those interests at the time of his death such that they were in his estate. No....more

1/31/2023  /  Jurisdiction , Probate Courts , Trusts

Appellate Court Affirmed Receivership Order Where Appellant Waived His Complaints By Not Securing Rulings And By Not Challenging...

In In re Estate of Vines, a probate court appointed a receiver over a business that was owned by a decedent. No. 01-21-00003-CV, 2022 Tex. App. LEXIS 2327 (Tex. App.—Houston [14th Dist.] April 12, 2022, no pet. history)....more

Appellate Court Held That It Did Not Have Jurisdiction Over A Probate Court’s Order Denying A Motion For Summary Judgment And...

In Janine v. McAfee, parties fought over who should be the administrator of an estate. No. 01-20-00717-CV, 2021 Tex. App. LEXIS 10101 (Tex. App.—Houston [1st Dist.] December 23, 2021, no pet. history). ...more

Court Affirmed Order Granting Injunction To Allow Successor Trustees To Manage A Business Owned By A Trust

In Clark v. Clark, two brothers sued a third brother regarding the third brother’s ability to be trustee of a trust due to a traumatic brain injury. No. 14-19-00604-CV, 2021 Tex. App. LEXIS 9866 (Tex. App.—Houston [14th...more

Court Holds That Probate Court Had Jurisdiction Over Inter Vivos Trust Dispute And That A Beneficiary Waived A Complaint About A...

In Goepp v. Comerica Bank & Trust, N.A., the settlors created inter vivos trusts and their three children were the remainder beneficiaries. No. 03-19-00485-CV, 2021 Tex. App. LEXIS 5461 (Tex. App.—Austin July 9, 2021, no pet....more

Co-Trustees Who Managed A Texas Trust With A Texas Beneficiary Had Sufficient Contacts With Texas To Be Subject To A Texas Court’s...

In Alexander v. Marshall, the original trustee was the beneficiary’s mother and the wife of the beneficiary’s father, who was the settlor. No. 14-18-00425-CV, 2021 Tex. App. LEXIS 1952 (Tex. App.—Houston [14th Dist.] March...more

Courts Rule On Jurisdictional Issues Involving Probate Orders

One of the most difficult areas for probate litigation is determining when a party has an order that is appealable. There have been several recent cases that discuss this important area of probate litigation....more

3/30/2021  /  Appeals , Jurisdiction , Probate

Court Reverses Receivership Order In Partnership Dispute Because The Probate Court Did Not Have Jurisdiction To Enter A...

In In re Estate of Hallmark, an executrix of an estate filed suit in probate court for declarations regarding a partnership and sued the other partners. No. 11-18-00187-CV 2020 Tex. App. LEXIS 7063 (Tex. App.—Eastland August...more

Court Had Jurisdiction To Declare That The Majority Of Co-Trustees Had The Authority To Sell Trust Property And The Declaration...

In Duncan v. O’Shea, three co-trustees brought a declaratory judgment action against a fourth co-trustee, seeking a declaration that the sale of trust real property was valid over the objection of the fourth co-trustee. No....more

Court Held That Statutory Probate Court Had Jurisdiction To Grant A Rule 202 Pre-Suit Deposition

In In the Estate of Nicholas, the temporary administrator of an estate and the decedent’s mother filed a Texas Rule of Civil Procedure 202 petition concerning a shootout at a residence by the City of Houston Police...more

Court Held That Statutory Probate Court Had Sole Jurisdiction Over Claims Against The Estate

In Hawes v. Peden, a client sued a deceased attorney’s estate and her law firm in district court due to the attorney failing to finish the representation before her death. No. 06-19-00053-CV, 2019 Tex. App. LEXIS 10841 (Tex....more

Contractual Jury Waivers in Trust and Estate Litigation in Texas

Individuals execute trusts and wills to determine how certain assets are to be managed and distributed. Those same individuals may want to have some control over the dispute resolution process for any conflicts that arise in...more

Trial Court Lacked Jurisdiction To Alter Its Previous Probate Order, and An Administrator Waived Any Challenge To A Damages...

In In the Estate of Brazda, the trial court found an administrator guilty of neglecting to timely distribute the property and ordered the administrator to pay one of the heir’s damages for the neglect. No. 01-18-00324-CV,...more

Court Found Trial Court Had Jurisdiction To Appoint Temporary Administrator Where A Will Contest Was Filed From A Muniment of...

In Chabot v. Estate of Sullivan, the decedent’s attorney probated a holographic will as a muniment of title. No. 03-17-00865-CV, 2019 Tex. App. LEXIS 2145 (Tex. App.—Austin March 20, 2019, no pet.)....more

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