In In the Est. of Ledbetter, Lonnie Ledbetter Jr. married Tawni in December 2023 at age 81, shortly after his wife of 44 years died. No. 02-25-00263-CV, 2025 Tex. App. LEXIS 9540 (Tex. App.—Fort Worth December 11, 2025, no pet.). After marriage, Lonnie changed his will to give 80% to Tawni and 20% to a foundation, disinheriting his children. There was evidence that Tawni had a history of deception, including lying about education and military service. There was evidence that after marriage, Lonnie’s children and longtime employees were isolated from him and that Tawni handled Lonnie’s finances after marriage. Lonnie died in April 2025, and his children immediately filed suit challenging new estate documents and also inter vivos transactions that benefited Tawni. The children sought a temporary injunction to effectively freeze any assets that were originally Lonnie’s so that Tawni could not dissipate them. Tawni filed a plea to the jurisdiction, alleging that the county court at law did not have jurisdiction over certain claims. The trial court denied the plea to the jurisdiction and granted the injunction, and Tawni appealed.
The court of appeals first addressed the jurisdictional issue. The case was originally in the county court and was transferred to the county court at law because it was contested. The county court at law judge recused himself, and a statutory probate judge was then appointed “to preside over the contested matters in [this case], with all rights, powers[,] and privileges held by the regular judge of the court assigned and the attendant jurisdiction of a Statutory Probate Court.” Tawni argued that the county court at law lacked subject matter jurisdiction over the trust claims, and she also argued that the appointment of statutory probate judge did not give the court jurisdiction over the trust claims.
The court of appeals noted that the county court at law had concurrent jurisdiction over probate proceedings with the county court. Id. (citing Tex. Est. Code § 32.002(b)). Regarding jurisdiction over trust disputes, the court noted:
Under Section 115.001(a) of the Texas Property Code, unless there is an exception listed in Section 115.001(d), the general rule is that “a district court has original and exclusive jurisdiction over all proceedings by or against a trustee and all proceedings concerning trusts.” Section 115.001(d) provides that the jurisdiction of the district court is exclusive except for jurisdiction conferred by law on certain courts, including a statutory probate court and a county court at law.
Id. The court held that because the statutory probate judge was assigned, he had the extended jurisdiction that a statutory probate court would have that included trust disputes:
By virtue of his assignment under Section 25.0022(h)(5), Judge Chu possessed “the jurisdiction, powers, and duties given by Sections 32.001, 32.002, 32.003, 32.005, 32.006, 32.007, 34.001, 1022.001, 1022.002, 1022.003, 1022.005, 1022.006, and 1022.007, Estates Code, to statutory probate court judges by general law.”25 Id. § 25.0022(i). Section 32.007 of the Estates Code provides that a statutory probate court has concurrent jurisdiction with the district court in “an action by or against a trustee” and “an action involving an inter vivos trust, testamentary trust, or charitable trust, including a charitable trust as defined by Section 123.001, Property Code.” That jurisdiction includes the ability to hear the trust actions at issue in this case. Thus, while Judge Chu was assigned to hear the underlying probate matter pursuant to Government Code Section 25.0022, his jurisdiction did not stop there. Because he also had the “jurisdiction, powers, and duties” given by Estates Code Section 32.00726—a section that gave him concurrent jurisdiction with the district court in matters involving trusts—the Hood County Court at Law also had jurisdiction over the trust claims.
Id.
The court then analyzed the temporary injunction order and held that it was not sufficiently specific:
Rule 683 states that an injunction order “shall be specific in terms” and “shall describe in reasonable detail and not by reference to the complaint or other document, the act or acts sought to be restrained.” “An injunction should inform the enjoined party of the acts he is restrained from doing without calling on him for inferences or conclusions about which persons might well differ and without leaving anything further for trial.” “That is, there can be no doubt about the conduct required to comply with the order, nor can there be any doubt about the conduct that would be a failure to comply with the order.” An injunction order, however, “is not required to specify each and every possible act that might constitute a violation,” and it “must be in broad enough terms to prevent repetition of the evil sought to be stopped.”...
Here, Tawni argues that the temporary injunction order violates Rule 683 because it makes vague references to “assets” and “funds” without identifying the enjoined assets or funds. Similarly, she contends that the order’s vague references to “accounts” without identifying the accounts with specificity also violate Rule 683. Trace and Kendall counter that the temporary injunction order does identify and define “the various accounts, estates, trusts, and foundations involved.” According to Trace and Kendall, the injunction “tells Tawni exactly what she cannot do.”
Having reviewed the temporary injunction order, we agree with Tawni that it does not inform her of the acts that she is restrained from doing without calling on her to make inferences or conclusions about which persons might well differ.
Id. The court concluded that the temporary injunction order violated Rule 683 by making vague references to “assets”, “funds”, and “accounts” without sufficient identification, requiring Tawni to make inferences about what was covered.
The court then went on and discussed whether there was evidence of an irreparable harm. The court noted:
For purposes of a temporary injunction, “[a]n injury is irreparable if the injured party cannot be adequately compensated in damages or if the damages cannot be measured by any certain pecuniary standard.” A plaintiff does not have an adequate remedy at law if the defendant is insolvent. Moreover, “money damages may be inadequate to compensate an injured party for the loss of property deemed to be legally ‘unique’ or irreplaceable.”
Id.
The trial court articulated two reasons for irreparable harm in the temporary injunction order: (1) the underlying assets are unique, and (2) Tawni would be judgment proof or not have adequate assets to satisfy a judgment against her concerning the underlying assets. Lonnie’s children also argued in their appellee’s brief, that Tawni will dissipate specific funds that would otherwise be available to satisfy a judgment. Even though the trial court did not express that as a reason for the injunction, the court of appeals held that “While the trial court did not specifically articulate this reason in the temporary injunction order, when reviewing the particulars of a temporary injunction, we are not limited to the reasons articulated by the trial court.” Id. The court held that there was evidence that Tawni would dissipate assets:
Here, evidence was presented at the injunction hearing that Tawni handled Lonnie’s finances after the marriage. According to Sinks, Tawni’s handling of Lonnie’s finances was inconsistent with Lonnie’s character prior to the marriage. After the marriage, Lonnie made several large purchases, including buying a jet and a yacht. Tawni purchased property in Florida after the marriage worth approximately $6 million. Although she initially testified that she had “never received any money from Lonnie or any of his entities to purchase” the Florida property, she later stated that she had used money that had been given to her by Lonnie or his entities to purchase the Florida property, noting that “[s]everal million dollars” was used. Notably, a ranch owned by both Lonnie and Tawni was listed for sale for approximately $18 million after the marriage. Viewing the evidence in the light most favorable to the trial court’s temporary injunction order and indulging every reasonable inference in its favor, Trace and Kendall sufficiently demonstrated that they would be irreparably harmed if Tawni were not enjoined from dissipating the assets of Lonnie’s estate and of the Ledbetter Trusts and that they have no adequate remedy by appeal.
Id. The court also held that there was sufficient evidence that Tawni did not have assets to pay a judgment. The court then analyzed the order and held that it was overly broad in that it did not account for expenses that were necessary to be paid to upkeep Lonnie’s assets. The court finally reviewed the evidence and determined that there was sufficient evidence of a probable right to recovery.