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Dallas, Texas  ·  Complex Commercial Litigation

Home Cases Nicholas Kreines, David P. Ryan, Liberty Mineral Partners LLC, Nak Resources INC., and CGR Oil and Gas, LLC v. ES3 Minerals, LLC

Nicholas Kreines, David P. Ryan, Liberty Mineral Partners LLC, Nak Resources INC., and CGR Oil and Gas, LLC v. ES3 Minerals, LLC

Fifteenth Court of Appeals 15-25-00027-CV active

Analysis

Business Court Modification of Temporary Injunction Fails Rule 684 Bond Requirement in Non-Compete Dispute

The Fifteenth Court of Appeals reversed in part a Business Court order modifying a temporary injunction against former ES3 Minerals employees and their competing venture, holding that the injunction bond failed to adequately protect appellants' interests under Rule 684 and that the order lacked adequate specificity regarding enjoined subsidiaries. The court also held that challenges to portions of the injunction imposed by the original district court—but not reviewed or reimposed by the Business Court—were not properly before it on appeal.

Joel Reese  |  Aug 05, 2026
Removal & Remand Section 25A.006 Temporary Injunction Non-Compete Agreements Rule 684

Chief Justice Brister Dissents on Transferred-Case Review Standards and Plenary Power in Business Court Appeal

In a dissenting memorandum opinion from the Fifteenth Court of Appeals reviewing a temporary injunction bond dispute transferred from district court to the Business Court, Chief Justice Brister argued that appellate review cannot be split between pre-transfer and post-transfer rulings and that the Business Court need not formally adopt previous orders to exercise plenary power over them. Brister would have declined to remand for further proceedings given an imminent trial date of December 8, 2025, arguing the case should simply proceed to trial.

Joel Reese  |  Aug 05, 2026
Temporary Injunction Interlocutory Appeal Transfer Procedure Plenary Power Standard of Review