CROSSOVER: Rule 683 Strict-Compliance Reversal: Temporary Injunction Void if Order Omits Reasons and Trial Setting

Amber Nicole Perez v. Survivors Network of Those Abused by Priests (SNAP), Inc., 13-26-00470-CV, August 13, 2026.

On appeal from 135th District Court of Victoria County, Texas

Synopsis

A temporary injunction order is void under Texas Rule of Civil Procedure 683 if the order itself does not state the reasons for its issuance and does not set the case for trial on the merits. Oral statements made by the trial court at the injunction hearing do not cure those omissions, so the proper appellate remedy is reversal and dissolution of the injunction.

Relevance to Family Law

This opinion matters in family law because temporary injunctive relief is routine in divorce, SAPCR, and property-preservation litigation. When a court signs a temporary injunction restricting transfers of community assets, limiting disclosures of confidential records, regulating possession of business information, or ordering removal of online content tied to the family dispute, Rule 683 strict compliance remains mandatory unless the order falls within a different statutory framework. For family law litigators, this case is a reminder that even a substantively justified injunction can be lost on appeal if the written order omits the reasons for issuance or fails to set the case for trial on the merits.

Case Summary

Fact Summary

The trial court signed a temporary injunction on June 8, 2026, in favor of SNAP and against Amber Nicole Perez. The order prohibited Perez from using or posting SNAP’s confidential information on social media and required her to remove specified Facebook posts concerning SNAP. Perez appealed under Civil Practice and Remedies Code section 51.014(a)(4), which authorizes interlocutory review of temporary injunction orders.

During the appeal, SNAP sought enforcement of the injunction through multiple motions, while the court of appeals had already granted a stay of trial-court proceedings. Among several appellate complaints, Perez argued that the injunction order was void because it did not comply with Texas Rule of Civil Procedure 683. The Thirteenth Court of Appeals agreed based on defects apparent on the face of the written order itself.

Issues Decided

• Whether a temporary injunction order is void under Texas Rule of Civil Procedure 683 when it fails to state the reasons for its issuance.
• Whether a temporary injunction order is void under Rule 683 when it fails to set the cause for trial on the merits.
• Whether the trial court’s oral pronouncements at the temporary injunction hearing can cure Rule 683 defects in the written order.
• What remedy is proper when a temporary injunction order is void for noncompliance with Rule 683.

Rules Applied

Rule 683 requires that every order granting an injunction must do two things relevant here: it must “set forth the reasons for its issuance,” and it must include an order “setting the cause for trial on the merits.” Texas appellate courts treat those requirements as mandatory, not aspirational.

The court relied principally on the following authorities:

• Texas Rule of Civil Procedure 683
• Qwest Commc’ns Corp. v. AT&T Corp., 24 S.W.3d 334, 337 (Tex. 2000) (per curiam), holding that a temporary injunction that does not strictly comply with Rule 683 is subject to being declared void and dissolved
• Freedom Commc’ns, Inc. v. Coronado, 372 S.W.3d 621, 623 (Tex. 2012) (per curiam), explaining that appellate courts lack jurisdiction to address the merits of appeals from void orders and may only determine voidness and enter appropriate relief
• In re Chaumette, 456 S.W.3d 299, 305 (Tex. App.—Houston [1st Dist.] 2014, orig. proceeding), emphasizing that the order itself must contain the reasons for issuance
• In re Corcoran, 343 S.W.3d 268, 269 (Tex. App.—Houston [14th Dist.] 2011, orig. proceeding), holding that failure to include a trial setting voids the order
• EOG Res., Inc. v. Gutierrez, 75 S.W.3d 50, 53 (Tex. App.—San Antonio 2002, no pet.), same
• Hoist Liftruck Mfg., Inc. v. Carruth-Doggett, Inc., 485 S.W.3d 120, 123 (Tex. App.—Houston [14th Dist.] 2016, no pet.), requiring the order to explain why irreparable injury will result absent injunctive relief

Application

The court’s analysis was straightforward and highly procedural. It did not evaluate whether SNAP may ultimately have been entitled to temporary injunctive relief on the underlying facts. Instead, it first examined whether the written order satisfied Rule 683, because that question determined whether there was even a valid injunction order for the appellate court to review on the merits.

On the first defect, the court held the order did not set forth the reasons for issuance. The opinion noted that the order failed to identify the reasons the trial court believed irreparable injury would result if the injunction did not issue, and it did not reference the facts the trial court relied on in reaching that conclusion. That omission was fatal under settled authority requiring the order itself to articulate the basis for extraordinary relief.

SNAP attempted to save the order by pointing to the trial court’s oral pronouncement at the hearing that SNAP had shown potential harm. The court rejected that position. Rule 683 compliance must appear within the four corners of the written order. Hearing comments, bench findings, or oral explanations are not substitutes for the mandatory contents of the injunction itself.

The second defect was equally simple and equally fatal: the order did not set the cause for trial on the merits. Rule 683 expressly requires that setting. Because both omissions appeared on the face of the order, the court concluded the injunction was void. Once the order was determined to be void, the court did not proceed to the remaining issues. It lifted the appellate stay, reversed the order, dissolved the temporary injunction, remanded, dismissed pending motions as moot, and directed immediate issuance of mandate.

Holding

The Thirteenth Court of Appeals held that a temporary injunction order that fails to state the reasons for its issuance does not comply with Rule 683 and is therefore void. A valid order must do more than recite a conclusion or imply harm; it must state, within the order itself, the reasons supporting issuance of temporary injunctive relief.

The court also held that a temporary injunction order that fails to set the case for trial on the merits is void under Rule 683. The trial setting requirement is mandatory, and omission of that setting is independently sufficient to require reversal and dissolution.

Finally, the court held that oral pronouncements at the injunction hearing cannot cure Rule 683 defects in the signed written order. Because the order was void, the appellate court’s role was limited to declaring it void, reversing it, dissolving the injunction, and remanding the case.

Practical Application

For Texas family law litigators, this case should prompt a fresh look at every temporary injunction form used in divorce and SAPCR practice. Family cases often involve requests to restrain the transfer of assets, preserve business records, prohibit cancellation of insurance, restrict dissemination of private communications or child-related information, and regulate conduct affecting possession or property. Where relief is sought through a temporary injunction governed by Rule 683, the order must be drafted with technical precision.

Several practical consequences follow.

First, do not assume the evidentiary hearing cures drafting defects. A strong evidentiary record, express bench comments, and even detailed oral findings are not enough if the signed order omits the reasons for issuance. If you are the movant, the safest course is to bring a proposed order that includes case-specific findings explaining the imminent and irreparable injury the injunction is meant to prevent.

Second, always include a trial setting in the order itself. In family cases, lawyers sometimes focus on obtaining immediate interim relief and assume the broader docket-control process will handle final settings later. This case shows that Rule 683 requires more. The order must set the cause for trial on the merits, and failing to do so risks immediate dissolution on appeal.

Third, this is a potent appellate and mandamus screening issue. If you represent the respondent to a temporary injunction in a family case, review the order before you spend time briefing evidentiary sufficiency, probable right to recovery, or overbreadth. If the order lacks reasons or a trial setting, you may have a threshold voidness argument that disposes of the injunction without reaching the merits.

Fourth, remember the distinction between family-code temporary orders and injunction practice under Rule 683. Some family law restraints arise under specific statutory mechanisms, while others are pursued as temporary injunctions. Practitioners should identify which procedural vehicle is being used, because Rule 683 strict-compliance arguments are especially important when the relief is framed and entered as a temporary injunction.

Checklists

Drafting a Rule 683-Compliant Temporary Injunction

• State the specific reasons for issuance in the body of the order.
• Identify the irreparable injury the court seeks to prevent absent injunctive relief.
• Tie the stated injury to case-specific facts, not generic conclusions.
• Avoid bare recitals such as “irreparable harm will occur” without explanation.
• Describe the prohibited or required conduct with precision.
• Set the cause for trial on the merits in the order itself.
• Confirm the signed order contains all required terms before leaving the hearing.

Reviewing a Family Law Injunction for Appellate Vulnerabilities

• Check whether the order expressly states the reasons for issuance.
• Check whether the order explains why a legal remedy is inadequate or why harm is irreparable.
• Check whether the order includes a trial setting on the merits.
• Compare the written order to the court’s oral rulings and confirm all required content appears in writing.
• Determine whether the relief granted exceeds the reasons stated in the order.
• Preserve objections, but remember a Rule 683 defect may render the order void even if not expressly raised below.

Presenting Temporary Injunctive Relief in Divorce or Custody Litigation

• Decide whether the requested relief is truly a Rule 683 temporary injunction or another form of temporary relief under the Family Code.
• Prepare a proposed order with tailored findings and a merits setting.
• Offer evidence supporting imminent and irreparable injury, especially for asset dissipation, destruction of records, disclosure of confidential information, or interference with property preservation.
• Ask the court to review the written order for Rule 683 compliance before signing.
• If the court announces findings orally, incorporate those findings into the written order immediately.

Responding to a Defective Temporary Injunction

• Review the order on the day it is signed for Rule 683 defects.
• Consider interlocutory appeal under Civil Practice and Remedies Code section 51.014(a)(4).
• Seek a stay where appropriate.
• Lead with voidness arguments before merits-based complaints.
• Request reversal and dissolution if the order omits reasons or a trial setting.
• On remand, be prepared for the opposing party to seek a corrected injunction order.

Family Law Crossover

The procedural rule established here is not family-law-specific, but it is highly consequential in family litigation because Rule 683 governs the validity of temporary injunction orders as written. The mechanism is formal and exacting: if a trial court grants a temporary injunction, the signed order must contain the reasons for issuance and must set the cause for trial on the merits. That issue can arise in a Texas family law matter whenever a party seeks injunctive relief to preserve community property, prevent disposition of business assets, restrict disclosure of private financial or medical information, protect electronic records, or prohibit conduct affecting property or litigation integrity pending final trial. The central lesson is procedural: the enforceability of interim injunctive relief depends not only on evidence and argument, but on whether the written order strictly complies with Rule 683.

Citation

Amber Nicole Perez v. Survivors Network of Those Abused by Priests (SNAP), Inc., No. 13-26-00470-CV, memorandum opinion (Tex. App.—Corpus Christi–Edinburg Aug. 13, 2026).

Full Opinion

Read the full opinion here

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