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Use Of Equitable Defenses In Breach Of Fiduciary Duty Litigation

It is not uncommon for beneficiaries to sue a trustee for actions that the beneficiaries had knowledge of but where they failed to object to that conduct for a period of time. In this circumstance, the trustee may want to...more

Court Affirmed Finding That An Applicant Was Not Equitably Adopted Where There Was No Evidence Of An Agreement To Adopt The...

In In re Estate of Hines, the trial court held that an applicant was not equitably adopted by the decedent in an heirship proceeding. No. 06-20-00007-CV, 2020 Tex. App. LEXIS 8000 (Tex. App.—Texarkana July 27, 2020, no pet.)....more

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 Dismissed Appeal By Pro Se Individual Who Could Not Represent An Estate

In Kankonde v. Mankan, an attorney appealed the entry of an arbitration award on behalf of his clients, a doctor and his practice. No. 08-20-00052-CV, 2020 Tex. App. LEXIS 7040 (Tex. App.—El Paso August 31, 2020, no pet....more

Administering Trusts in Recessions: Trust Loans to Beneficiaries

Beneficiaries often request that a trustee make them a loan from trust property. In an economic downturn, such requests are even more prevalent. As a general rule, a trustee should not want to make a loan to a beneficiary as...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 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 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

Court Affirmed Arbitration Decision Because Multiple Documents Regarding The Resignation And Appointment Of A Trustee Constituted...

In Ruff v. Ruff, a beneficiary of a trust sued a former trustee, and that dispute was sent to arbitration. No. 05-18-00326-CV, 2020 Tex. App. LEXIS 6344 (Tex. App.—Dallas August 11, 2020, no pet. history)....more

Receiverships in Trust and Estate Litigation in Texas

A plaintiff in a trust or estate dispute often needs to seek a remedy before trial to protect it from immediate injury, to protect the assets made the basis of the suit, or to discover the real condition of the parties’...more

Co-Trustees Can Sue To Remove A Co-Trustee Due To Hostility

In Ramirez v. Rodriguez, three co-trustees sued a fourth trustee to have him removed due to his hostile actions: he “has engaged in a pattern of creating hostility and friction that impedes and/or affects the operations of...more

Appellate Court Held That Judgment Construing A Trust Was Enforceable And Had Effect When The Trust Was Later Challenged

In Neal v. Neal, the court of appeals affirmed a trial court’s judgment resolving who were the correct beneficiaries of a trust. No. 05-19-00364-CV, 2020 Tex. App. LEXIS 4514 (Tex. App.—Dallas June 17, 2020, no pet. history)....more

What Did He Say? A Court Reverses A Statutory Probate Court’s Order Because There Was No Record

In Smith v. Malone, parties litigated the propriety of certain transactions in an estate proceeding before a statutory probate court. No. 01-19-00266-CV, 2020 Tex. App. LEXIS 4622 (Tex. App.—Houston [1st Dist.] June 23, 2020,...more

Companies Should Know When Their Customers Die: Court Rendered Judgment For An Estate Who Was Sued By An Annuity Company For...

In In re Estate of Scott, an annuity company sued a customer’s estate for not reporting the death of his wife, which resulted in him receiving larger monthly payments after her death than he was entitled to under the...more

Court Affirms Default Judgment Against A Foreign Corporate Fiduciary Because Service Was Proper Under The Texas Estates Code

In United States Bank Nat’l Ass’n v. Moss, U.S. Bank (USB) sought to vacate a default judgment in an underlying suit involving title to real property through a bill of review based on allegedly improper service under the...more

Administering A Trust In A Recession: Securing Loans For Beneficiaries

Beneficiaries often request that a trustee secure a loan from a third party. In an economic downturn, such requests are even more prevalent. As a general rule, a trustee should not want to do so as it should assume that the...more

Magistrate Suggests Dismissing A Settlor’s Claim Against Trust Protector Because Of A Lack Of Fiduciary Duty

In Ron v. Ron, a wife created a trust with her husband as a trustee, a friend as a trust protector, and their children as the beneficiaries. No. 3:19-CV-00211, 2020 U.S. Dist. LEXIS 52507 (S.D. Tex. February 4, 2020)....more

Presentation: Joint Account Litigation in Texas

David F. Johnson, lead writer for the Texas Fiduciary Litigator blog, presented his paper on “Joint Account Litigation in Texas” to the Texas Bankers Association via a webinar on April 29, 2020. This presentation addresses...more

Court Dismissed Appeal From Order Denying Motion To Remove Executor Because Attorney’s Fees Claim Was Still Unresolved

In Bethany v. Bethany, a party filed a motion to remove his brother as executor of their mother’s estate. No. 03-19-00532-CV, 2020 Tex. App. LEXIS 2350 (Tex. App.—Austin March 20, 2020, no pet.)....more

Administering a Trust In a Recession: Issues Surrounding Trust Loans to Beneficiaries - Presentation

David F. Johnson, lead writer for the Texas Fiduciary Litigator blog, discusses the topic of beneficiaries requesting loans from trustees. There are multiple issues that arise regarding the trustee’s authority to do so under...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 Holds That A Deceased Testamentary Trust Beneficiary Can Still Be A Beneficiary

In In the Estate of Mendoza, a decedent’s son’s children filed a petition claiming their entitlement to their father’s beneficial interest in a trust created under the decedent’s will. No. 04-19-00129-CV, 2020 Tex. App. LEXIS...more

Notary Services In A World of Social Distancing: Online Notarization

Fiduciary relationships often require a party to notarize a document. For example, a party may need to or want to use notary services for each of the following: a person may execute new trust or estate documents, a...more

Administering Trusts In A Recession: The Support Trust/HEMS Distribution Standard

When the economy has a downturn, trustees are under more pressure to make distributions. Beneficiaries lose jobs, their individual asset portfolios decrease, and they may make the decision to go back to school....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

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