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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 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

Court Reversed Summary Judgment And Held That There Was A Fact Issue On Whether The Testator Had Mental Capacity To Execute A Will

In Castello v. Ex’r of the Est. of Castello, the decedent died leaving a will that left his property to his wife “for life” and then to his three children by a prior marriage. No 03-22-00012-CV 2023 Tex. App. LEXIS 4454 (Tex....more

Court Affirms Order Voiding Marriage Between Decedent And His Niece

In Allebach v. Gollub, the decedent had three children, and after he died, one of them filed a will contest and a claim that the decedent’s marriage to his second wife was void. No. 14-22-00272-CV, 2023 Tex. App. LEXIS 3469...more

The Texas Supreme Court Affirms A Summary Judgment For A Fiduciary Defendant Based On The Statute Of Limitations And The Duty To...

The Court noted that a claim generally accrues when the defendant’s wrongful conduct causes the claimant to suffer a legal injury. Id. The Court also noted that the discovery rule can defer accrual of limitations...more

Court Affirmed Summary Judgment For A Financial Advisor Due To The Dead Man’s Rule Arising From Claim That He Failed To Change A...

In Donnelly v. Donnelly, a widow sued her deceased husband’s son for failing to change the beneficiary designation on the husband’s IRA to name her. No. 14-21-00592-CV, 2022 Tex. App. LEXIS 7615 (Tex. App.—Houston October 13,...more

Court Affirmed Summary Judgment For Bank On Non-Customer’s Aiding And Abetting Breach Of Fiduciary Duty Claim

In Ahmed v. Bank of Whittier, a party sued a bank for aiding and abetting breach of fiduciary duty by assisting the plaintiff’s attorney in improperly depositing settlement funds. No. 05-21-00058-CV, 2022 Tex. App. LEXIS 2987...more

Court Holds That Trust Was Not Ambiguous And Provided The Trustee Discretion In Making Income Distributions

In Wells Fargo, N.A. v. Clower, a trustee filed suit for declaratory relief regarding its discretion to make income distributions. No. 02-20-00058-CV, 2021 Tex. App. LEXIS 7675 (Tex. App.—Fort Worth September 16, 2021, no...more

Court Reversed Summary Judgment Against Trustee Where Beneficiary’s Affidavit Evidence Was Conclusory

In McEndree v. Volke, a beneficiary sued a trustee, her former step father, for breaching fiduciary duties. No. 11-19-00351-CV, 2021 Tex. App. LEXIS 7856 (Tex. App.—Eastland September 23, 2021, no pet. history). ...more

Court Held That The Estate Planning Privity Rule Barred Granddaughter’s Claim For Malpractice Against Her Grandmother’s Attorneys...

In Flores v. Branscomb PC, before her death, the decedent hired counsel to prepare a new will. No. 13-18-00411-CV, 2021 Tex. App. LEXIS 4612 (Tex. App.—Corpus Christi June 10, 2021, no pet. history)....more

Wife’s Fraudulent Transfer Claim Against Husband For Transferring Business Interests To Trust Failed Due To The Statute Of Repose

In Austin v. Mitchell, a wife filed suit alleging her ex-husband fraudulently transferred a portion of his limited partnership interest in a family limited partnership to a trust for the benefit of his children. No....more

Court Found That There Was A Fact Question On Whether Officers Violated Fiduciary Duties By Obtaining A Side Bonus From A...

A business divorce may mean that the owners need to sell the business or the business’s assets. In the following case, some of the owners/officers took advantage of a sale transaction to benefit from that transaction at the...more

Business Divorce: Court Held That Parties Did Not Form A Partnership Where Certain Express Conditions Precedent Were Not Met

Parties often begin a business together without thinking through all of the legal details that define their rights. When they eventually divorce, they need to resort to the language in agreements that they entered into and...more

Court Holds That Bank Did Not Owe Fiduciary Duties To Depositor/Customer

In Denson v. JPMorgan Chase Bank, N.A., Sandra Denson went to her bank to deposit $730 when a $50 bill became temporarily stuck in the cash counting machine, causing the teller to miscount the amount of the deposit as $680....more

Court Holds That Holographic Will Was Not Valid As There Was No Signature

In In the Estate of Hohmann, the decedent died without leaving an executed will, but his caretaker found a hand written document wherein the decedent stated his wishes for his property. No. 04-20-00237-CV, 2020 Tex. App....more

Court Holds That A Trustee Had The Power To Sell Trust Property To An Affiliate, Though Such An Act May Be In Breach Of A Duty

In Pense v. Bennett, the ward in a guardianship proceeding sued to invalidate the sale of real property from a trust created for his benefit to an affiliate of the trustee. No. 06-20-00030-CV, 2020 Tex. App. LEXIS 8002 (Tex....more

Court Addresses Claims Against A Trustee Arising From The Management Of A Limited Partnership Interest

In Benge v. Thomas, a settlor created a trust and appointed her daughter, Missi, as the trustee. No. 13-18-00619-CV, 2020 Tex. App. LEXIS 6888 (Tex. App.—Corpus Christi August 27, 2020, no pet.)....more

Court Affirmed Summary Judgment For Successor Trustees Due To A Clause Stating That They Had No Duty To Investigate Former...

In Benge v. Roberts, a beneficiary sued co-trustees and sought to remove them for breaching duties by not considering claims against a former trustee. No. 03-19-00719-CV, 2020 Tex. App. LEXIS 6335 (Tex. App.—Austin August 12,...more

Old College Friends Do Not Generally Owe Fiduciary Duties To Each Other

In Gill v. Grewal, the suit arose out of a failed business venture between old college friends. No. 4:14-CV-2502, 2020 U.S. Dist. LEXIS 104461 (S. D. Tex. June 15, 2020)....more

Texas Courts Conflict On Whether Contingent Remainder Beneficiaries Have Standing To Assert Claims Regarding Trust Administration

Texas has recently had two opinions that seemingly take opposite views on whether a contingent remainder beneficiary has standing to sue a trustee for trust administration issue. In In re Estate of Little, a settlor of a...more

Court Reverses Summary Judgment On The Issue Of Whether A Testatrix Had The Mental Capacity To Execute A New Will

In In the Estate of Mahaffey, a testatrix executed a new will nine days before she died of cancer. No. 04-19-00122-CV, 2019 Tex. App. LEXIS 11171 (Tex. App.—San Antonio December 27, 2019, no pet. history)....more

Court Reverses Summary Judgment On Breach Of Fiduciary Duty Claim Because There Was A Fact Issue On The Running Of The Statute Of...

In Melton v. Waddell, a sister sued her brother for breach of fiduciary duty for misapplying funds in a joint account and not properly allocating revenues from real estate that they owned as tenants in common. No....more

Presentation: Summary Judgments in Texas

David F. Johnson recently presented his paper on “Summary Judgments in Texas” at the State Bar of Texas’s Advanced Civil Appellate Course in Austin, Texas. This presentation included a discussion of the finality of summary...more

Statute of Limitations Barred Estate Representative’s Claim To Void Beneficiary Designations

In Sanders v. Hathaway, the decedent’s estate’s representative sued her sister for various claims arising from the decedent’s beneficiary designation changes, deed transfers, and accounts payable on death changes that...more

In A Suit To Reform A Trust, A Texas Court Holds That There Was A Fact Issue On The Settlors’ Intent And Remanded For A Fact...

In In re Ignacio G. & Myra A. Gonzales Trust, a couple formed a trust and named their daughter as the trustee. No. 06-19-00014-CV, 2019 Tex. App. LEXIS 4648 (Tex. App.—Texarkana June 6, 2019, no pet. history)....more

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