A Texas woman can no longer be kept 500 feet away from her family’s trust property after an appeals court overturned restrictions imposed by a lower court. The ruling, delivered on November 10, came in a dispute involving Jensen Chelsea Anderson, her aunt Suzanne Tolbert Sakiewicz and Suzanne’s husband, Edward P. Sakiewicz.The restrictions had prevented Anderson from approaching the trust’s property in Gonzales, Texas. She was also barred from going near Suzanne and Edward, handling assets belonging to the trust or claiming that she had the authority to act on its behalf. The appeals court has now removed these restrictions after finding that the order imposing them did not follow mandatory legal procedures.According to the judgment, the dispute centres on the Barbara Tolbert Revocable Trust. Suzanne is Barbara Tolbert’s daughter and a co-trustee, while Anderson is Barbara’s granddaughter. Both have claimed an interest in the trust as beneficiaries. However, the appeals court made no ruling on either claim and did not decide who should receive the trust assets.The family disagreement had already reached court in 2023. Suzanne’s brother, Gordon Gerald Tolbert, who is also a co-trustee, had sued Suzanne, Edward and an associated company, Sakabbage LLC. He accused them of misconduct relating to the trust. Suzanne subsequently filed a counterclaim against Gordon. Those claims remain part of the wider dispute and were not decided in Anderson’s appeal.
Dispute over Texas property brings granddaughter into case
Anderson’s involvement in the legal proceedings became an issue in June 2024. Suzanne then alleged that her niece had improperly moved into a property owned by the trust in Gonzales.Suzanne asked the court to protect the property through a temporary injunction. Her filing also raised concerns about Gordon’s performance of his responsibilities as co-trustee. However, it did not directly seek an order against Anderson.At that point, Anderson was not a party to the lawsuit and had not appeared before the trial court. The court initially granted Suzanne’s request for an injunction, but that restriction later expired under its own terms.The matter took a different turn in April 2026, when Suzanne and Edward filed another application. This time, they specifically sought restrictions against Anderson.Their application sought to stop her from presenting herself as a trustee, dealing with trust assets or spending money belonging to the trust. They also wanted her to hand over access to properties she held and provide a sworn account of business she had conducted while claiming to act as a trustee.Suzanne and Edward further asked the court to impose sanctions on Anderson and make her pay their legal expenses. Anderson filed her answer and counterclaim on May 11, 2026.
Lower court imposed restrictions on Anderson
The trial court heard the application on May 14. After hearing arguments from Suzanne and Edward’s lawyer and taking limited testimony from Anderson, the judge decided to grant the requested injunction.The written order went beyond restricting Anderson’s dealings with trust assets. It also prohibited her from approaching the Gonzales property within 500 feet. The same distance restriction applied to Suzanne and Edward.Anderson was barred from interfering with the property. This included changing its locks, disconnecting security cameras or utility services, and causing damage. She was also prohibited from taking possession of any property held by the trust or trying to exercise control over it.The order prevented her from keeping Suzanne and Edward out of the Gonzales property. It also barred her from telling others that she had authority to act under the trust or that she was a beneficiary.Although the order described these restrictions as permanent, the appeals court later examined the circumstances in which they had been imposed. Anderson challenged the decision on May 28, 2026.
Appeals court explains why the order could not stand
The Fourth Court of Appeals in San Antonio examined whether the lower court had followed the rules required for granting an injunction.A key issue was the nature of the May 14 order. Although the trial court had described the restrictions as permanent, the appeals judges looked at when and why they were imposed.The application filed by Suzanne and Edward had sought temporary relief. The restrictions also came into force while the main family lawsuit was still pending. No final decision had been made in that case.The appeals court therefore treated the order as a temporary injunction. This allowed it to examine Anderson’s challenge before the entire family dispute had reached a final decision.The judges then found two important omissions in the lower court’s order. Under Texas Rule of Civil Procedure 683, a temporary injunction must include a date for the trial that will decide the main issues in the case.This requirement is intended to ensure that temporary restrictions do not continue indefinitely without a full hearing on the dispute.Another provision, Rule 684, requires the applicants to provide security, with the court specifying the amount. The May 14 order did not include such an amount.The appeals court found that the lower court’s order had neither fixed a trial date nor stated the required security amount. These were not optional details. Both rules set out compulsory conditions for granting a temporary injunction.Suzanne and Edward argued that Anderson had not raised the objections at the appropriate stage. However, the appeals judges noted that she had already submitted a written objection concerning the absence of the required cash bond.The court also pointed out that an injunction failing to meet the requirements of Rule 683 could be invalid even if the affected person had not specifically raised that objection.
Court sends case back for further proceedings
The appeals court accepted Anderson’s challenge to the procedural defects. It ruled that the May 14 order was void and could not remain in force.The judges reversed the lower court’s order, dissolved the injunction and sent the matter back to the trial court for further proceedings.Anderson had raised four other challenges to the restrictions. However, the appeals court did not examine them because its decision on the first issue was sufficient to dispose of the appeal.