The Texas Court of Appeals has reversed an injunction that had been granted against Jensen Chelsea Anderson in a family trust dispute. The court's decision, delivered on November 10, 2026, affects Anderson and her relatives involved in the Barbara Tolbert Revocable Trust. This ruling is significant as it addresses the procedural requirements for issuing injunctions in Texas.

The dispute centers around property held by the Barbara Tolbert Revocable Trust. Anderson is the granddaughter of Barbara Tolbert and claims to be a beneficiary of the trust. Her aunt, Suzanne Tolbert Sakiewicz, is a co-trustee of the trust and is also a beneficiary. The conflict escalated when Suzanne's brother, Gordon Gerald Tolbert, filed a lawsuit against her and her husband, Edward P. Sakiewicz, alleging misconduct regarding the trust.

This legal battle began in 2023 when Gordon accused Suzanne and Edward of mismanaging the trust. Suzanne later countered with her claims against Gordon. The court filing did not resolve these claims, leaving the underlying issues still pending. In June 2024, Suzanne filed a second amended counterpetition, alleging that Anderson had improperly taken residence in property held by the trust in Gonzales, Texas. This led to a request for a temporary injunction, which was granted but later expired.

On April 22, 2026, Suzanne and Edward filed a new motion directly targeting Anderson. They sought a temporary restraining order and injunction to prevent her from acting as a trustee and to require her to provide access to trust property. The trial court held a hearing on May 14, 2026, where it decided to grant the injunction against Anderson, which included several restrictions on her actions regarding the trust property.

The trial court's order specifically prohibited Anderson from coming within 500 feet of the Gonzales property and from communicating as if she had authority over the trust. Following this decision, Anderson filed an appeal challenging the injunction.

In its ruling, the Texas Court of Appeals, led by Justice Lori I. Valenzuela, found that the injunction was void due to non-compliance with the Texas Rules of Civil Procedure. The court noted that the order did not set a trial date or specify the amount of security required, which are mandatory requirements for issuing a temporary injunction.

The court ruled, "The May 14, 2026 temporary injunction order at issue in this case does not set a trial date or an 'amount of security to be given by the applicant[s].'"

As a result, the court reversed the trial court's order, dissolved the injunction, and remanded the case for further proceedings. This ruling underscores the importance of adhering to procedural rules when seeking injunctions in Texas.

The impact of this ruling is significant for Anderson, Suzanne, and Edward, as it allows Anderson to regain her rights concerning the trust without the constraints imposed by the injunction. It also serves as a reminder to all parties involved in trust disputes about the necessity of following legal procedures to ensure the validity of court orders.

Moving forward, the case will return to the trial court for further proceedings. The court will need to address the underlying issues regarding the trust and the claims made by both Suzanne and Gordon. It remains to be seen whether there will be further appeals or additional motions filed by the parties involved.