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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 Affirmed Order Reinstating Receivership While Case Was On Appeal

In Bogle v. Bass, a trial court granted a motion for receivership in a trust dispute under “under the rules and principles of equity” under Texas Civil Practice and Remedies Code Section 64.001(a)(6). No. 03-23-00491-CV, 2024...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 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

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 Affirms Modification Of Trust That Relied On Extrinsic Evidence And Contradicted Express Trust Terms

In In re Poe Trust, a co-trustee of a trust filed suit to modify the trust to change distribution provisions, increase the number of trustees, and change the method for trustees to vote on issues as well as other...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 Held That Deed For Common Area To Homeowners’ Association Did Not Create A Trust For The Members

In BLF LLC v. Landing at Blanco Prop. Owners Ass’n, member of a home owners association sued to prevent the association from selling certain common area property. No. 03-22-00423-CV, 2023 Tex. App. LEXIS 9300 (Tex....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

Texas Court Holds That Venue Is Appropriate In County Where The Trustee Resided Under The Texas Trust Code, Which Trumps Other...

In Parker v. Filip, a trust owned a limited partnership interest and the partnership owned real property in Fayette County, Texas. No. 14-23-00372-CV, 2023 Tex. App. LEXIS 6976 (Tex. App.—Houston [14th Dist.] August 31, 2023,...more

Colorado Case Holds That A Beneficiary’s Lifestyle Is Judged At The Time That The Settlor Dies Or When The Trust Becomes...

In Reece Trust v. Reece, a husband created a trust for his wife, and they then began divorce proceedings. No. 22CA1393, 2023 COA 89, 2023 Colo. App. LEXIS 1456 (Colo. App. September 28, 2023)....more

Court Held That The TCPA Does Not Apply To Claim Involving Texas Trust Code Section 113.28 And Suits Against Third Parties

In McCoy v. McCoy, trust beneficiaries sued the trustee for breaching his fiduciary duties by pursing claims against a third party when they instructed him not to do so. No. 08-23-00119-CV, 2023 Tex. App. LEXIS 6604 (Tex....more

[Webinar] Fiduciary Litigation Update 2022-2023 - December 19th, 10:00 am - 11:00 am CT

This update will address the following issues: whether a party has a right to jury trial in trust modification and other similar actions, what are the standards for pretrial receivership and injunctive relief in trust...more

Courts Have Ordered Trial Courts To Grant TCPA Motions To Dismiss Based On No-Contest Clause Claims

The Texas Legislature created a statute to protect parties’ rights to freedom of speech and to petition the courts: the Texas Citizen’s Participation Act (TCPA). See Tex. Civ. Prac. & Rem. Code Ann. §§ 27.001-.011....more

Court Holds That TCPA Does Not Apply To Claim Involving Beneficiaries Opposing A Trustee’s Decision To Bring Claims Against Third...

In McCoy v. McCoy, trust beneficiaries (daughters) sued the trustee (father) for maintaining a claim against a third party (mother) after they notified him of their opposition under section 113.028 of the Texas Trust Code....more

Court Rules That There Is No Right To A Jury Trial In A Trust Modification Suit And Affirms The Modifications Of A Trust

First Appellate Decision. 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...more

Court Affirms Receivership In Trust Case Based Solely On An Alleged Failure To Disclose And Did Not Require Traditional Equitable...

In Moody Nat’l Bank v. Moody, a beneficiary sued a trustee regarding several allegations of breach of fiduciary duty. No. 14-21-00096-CV, 2022 Tex. App. LEXIS 7844 (Tex. App.—Houston [14th Dist.] October 25, 2022, pet....more

Court Affirms Finding Of An Oral Trust And Breach Of Duty By The Trustee

In Ahlgren v. Ahlgren, plaintiffs sued a defendant alleging that the defendant was a trustee of an oral trust who breached duties by refusing to return certain property. No. 13-22-00029-CV, 2023 Tex. App. LEXIS 4182 (Tex....more

Court Affirmed Temporary Injunction Precluding A Surviving Spouse From Acting As Trustee Of A Trust

In Kirkland v. Kirkland, a husband and wife created a revocable trust. No. 02-22-00469-CV, 2023 Tex. App. LEXIS 3598 (Tex. App.—Fort Worth May 25, 2023, no pet. history)....more

[Webinar] A Trustee’s Duty To Disclose - June 13th, 10:00 am - 11:00 am CT

David F. Johnson will address the complex issues surrounding a trustee’s duty to disclose and will compare Texas law and the Uniform Trust Code on this topic. He will address disclosure requirements under trust documents and...more

Trust Issues in Divorce Proceedings - Presentation - May 2023

David F. Johnson presented to the Tarrant County Probate Bar Association on May 4, 2023, on the topic of “Trust Issues in Divorce Proceedings.” This program discussed some of the many trust issues that arise in divorce...more

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