Background and Procedural Posture

Three related charitable foundations—The Highland Dallas Foundation, Inc., The Highland Kansas City Foundation, Inc., and The Highland Santa Barbara Foundation, Inc.—filed a mandamus petition with the Fifteenth Court of Appeals on November 26, 2025, seeking relief from an order entered by Judge William Whitehill of Business Court Division 1B. The underlying litigation, styled The Highland Dallas Foundation, Inc., The Highland Kansas City Foundation, Inc., and The Highland Santa Barbara Foundation, Inc. v. Mark Patrick, DFW Charitable Foundation, CDMCFAD, LLC, Charitable DAF GP, LLC and CDH GP, Ltd., involves a dispute between the foundation relators and Mark Patrick along with several entities associated with charitable donor-advised funds and related structures.

The Mandamus Petition

Relators sought a writ of mandamus directing Judge Whitehill to set aside his order dated September 18, 2025, entered in trial court cause number 25-BC01B-0027. The memorandum opinion provides no detail regarding the substance of the challenged order or the specific grounds on which relators sought mandamus relief.

The Court's Decision

In a memorandum opinion issued February 24, 2026, the Fifteenth Court of Appeals denied the petition. The per curiam opinion, issued by a panel consisting of Chief Justice Brister and Justices Field and Farris, disposed of the petition in a single substantive sentence:

Relators have not established they are entitled to mandamus relief.

The court provided no further analysis or explanation for its decision.

Implications for Practice

The decision reflects the appellate court's denial of mandamus relief from an interlocutory Business Court order. The opinion's brevity offers limited guidance for practitioners regarding what specific deficiencies led to the denial or what showing would have been required to obtain the requested relief.