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Texas Legislature Extends The Rule Against Perpetuities To 300 Years For Trusts

The Texas Legislatures recently passed a bill that takes effect on September 1, 2021 that extends the rule against perpetuities to 300 years for trusts. The Legislature forwarded the bill (HB 654) to the governor on May 20,...more

Court Affirmed Trial Court’s Reformation Of A Will To Omit The Word “Personal” From The Term “Property” In A Residuary Clause

In Odom v. Coleman, a brother and a sister sued each other regarding their father’s estate. No. 01-19-00669-CV, 2020 Tex. App. LEXIS 9551 (Tex. App.—Houston [1st Dist.] December 8, 2020, no pet.)....more

Court Holds That Allegations Related To A Trustee’s Filing Of Suit Did Fall Under The Protection Of The Texas Citizens...

In Marshall v. Marshall, a son, who was a trust beneficiary, sued his mother and brother alleging breaches of fiduciary duty and sought a declaratory judgment that they violated an in terrorem clause of the will. No....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

[Webinar] Fiduciary Litigation Update: 2019-2020 - December 15th, 10:00 am - 11:15 am CT

This presentation will cover Texas cases dealing with fiduciary issues over the survey period. Some of the issues involve the removal of a trustee, the resignation of a trustee, the production of confidential trust...more

Court Affirmed Finding That Testator Had Capacity To Execute A Will, Was Not Unduly Influenced, And That The Appointment of...

In In the Estate of Flarity, a son of the testator challenged the trial court’s probating of a 2004 will and the appointment of two of his siblings, named in that will, as executors. No. 09-19-00089-CV, 2020 Tex. App. LEXIS...more

Court Holds That Devise Of “Personal Property” In A Will Included Tangible And Intangible Property, Including Money In Bank...

In In re Estate of Debra E. Hunt v. Arabia Vargas, a trial court granted summary judgment interpreting a will to devise a large share of the testatrix’s personal property to her life partner. No. 01-19-00216-CV, 2020 Tex....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 Holds That A Defendant Cannot File A No-Evidence Summary Judgment Based On A Self-Interested Transaction Due To The...

In In re Estate of Klutts, a son held his mother’s power of attorney when he assisted in securing a new 2008 will, which enhanced his share of the estate. No. 02-18-00356-CV, 2019 Tex. App. LEXIS 11063 (Tex. App.—Fort Worth...more

Court Holds That Will Contestant Was Not Estopped From Challenging The Will Due To Accepting Assets

In "In the Estate of Johnson," a decedent’s daughter filed a will contest after accepting over $146,000 from the estate. No. 05-18-01193-CV, 2019 Tex. App. LEXIS 9646 (Tex. App.—Dallas November 4, 2019, no pet.). ...more

Presentation - Texas Fiduciary Litigation Update: 2018-2019

David F. Johnson, lead writer for the Texas Fiduciary Litigator blog, discusses Texas fiduciary litigation case law and addresses issues such as merger of trusts, Gun Trusts, statute of limitations, quasi-estoppel,...more

Presentation: The Use of Arbitration, Forum-Selection, Jury-Waiver Clauses in Trust & Estate Litigation

David F. Johnson presented his paper “The Use of Arbitration, Forum Selection, and Jury-Waiver Clauses in Trust and Estate Litigation in Texas” to the Texas Bar Association’s Fiduciary Litigation Course in San Antonio on...more

Court Holds That Testatrix Died Partially Intestate And That The Term “Personal Effects” In A Will Did Not Include Real Property

In In re Estate of Ethridge, a testatrix signed a will that provided that “all my personal effects” would be devised to her nephew in law and that her half interest in a home went to another person. No. 11-17-00291-CV, 2019...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

Court Affirms Trial Court’s Order Admitting Will To Probate Over An Allegation Of Forgery

In Austin v. Austin, after the decedent passed, his daughters probated an April 2016 will, and his wife then sought to probate a December 2016 will. No. 03-18-00678-CV, 2019 Tex. App. LEXIS 8255 (Tex. App.—Austin September...more

Court Holds That A Testamentary Trust Did Not Fail Because The Primary Beneficiary Predeceased The Decedent

In In re Estate of Moore, a decedent executed a will that provided that the residuary of his estate would be held in trust for his mother, and such trust would terminate on her death with the assets then passing to certain...more

Texas Court Concludes There Was A Fact Question As To Whether A Hand-Written Document Was A Will

In In re Estate of Silverman, a trial court granted a will contestant’s summary judgment and denied a handwritten document’s admission to probate as the last will of the decedent. No. 14-18-00256-CV, 2019 Tex. App. LEXIS 4579...more

Texas Statutes Now Allow A Court To Modify Or Reform An Unambiguous Will

I. Introduction Historically, Texas courts could not resort to extrinsic evidence to construe an unambiguous will. San Antonio Area Foundation v. Lang, 35 S.W.3d 636 (Tex. 2000)....more

Court Affirms Finding Of Undue Influence Regarding Execution Of Will

In In re Estate of Russey, the decedent was going through a divorce and signed a will. No. 12-18-00079-CV, 2019 Tex. App. LEXIS 1536 (Tex. App.—Tyler February 28, 2019, no pet. history). ...more

Codicil Was Properly Rejected Because It Did Not Adequately Refer To Last Will And Testament

In In the Estate of Hargrove, two daughters offered their mother’s last will and testament dated in 2017 for probate. No. 04-18-00355-CV, 2019 Tex. App. LEXIS 1703 (Tex. App.—San Antonio March 6, 2019, no pet. history). Their...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

The Texas Supreme Court Holds That The Only Consideration In Probating A Will After The Four-Year Limitations Period Is Evidence...

In Ferreira v. Butler, a husband and wife divorced, and the husband married a second wife. No. 17-0901, 2019 Tex. LEXIS 375 (Tex. April 12, 2019). The second wife died, and the husband never probated her will, which left...more

Court Holds That Testator’s Granddaughter Was A Beneficiary Of The Will

In McDaniel v. Meador, parties sued for declaratory relief regarding whether a granddaughter was a beneficiary of a will. No. 01-18-00041-CV, 2019 Tex. App. LEXIS 1315 (Tex. App.—Houston [1st Dist.] February 21, 2019, no pet....more

Court Holds That A Will Left A Partial Intestacy

In Sullivan v. Hatchett, a husband executed a will giving his wife a life estate in his property. No. 07-17-00296-CV, 2019 Tex. App. LEXIS 980 (Tex. App.—Amarillo February 11, 2019, no pet. history)....more

Court Holds That There Was Insufficient Evidence To Establish That Account Beneficiary Designations Were Executed As A Result Of...

In Fielding v. Tullos, an administrator of a decedent’s estate brought claims against the decedent’s housekeeper for undue influence and other related claims arising from the execution of new account beneficiary designations...more

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