Background
Amber Nicole Perez appealed a Victoria County district court order granting Survivors Network of Those Abused by Priests (SNAP), Inc. a temporary injunction. The June 8, 2026 order barred Perez from using or posting SNAP’s confidential information on social media and required her to remove several Facebook posts concerning the organization.
During the appeal, SNAP filed several motions seeking enforcement of the injunction based on Perez’s alleged noncompliance. Perez raised six appellate issues, including that the injunction was void because it failed to satisfy Texas Rule of Civil Procedure 683.
The Court’s Holding
The Thirteenth Court of Appeals held that the temporary injunction was void for failure to comply strictly with Rule 683. The written order did not state why irreparable injury would occur without injunctive relief, identify the facts supporting that conclusion, or set the case for trial on the merits.
The court rejected SNAP’s reliance on the trial court’s oral statement that SNAP had shown potential harm because Rule 683 requires the written order itself to state the reasons for its issuance. Because a void injunction permits appellate review only of its invalidity and the resulting disposition, the court did not address Perez’s remaining merits-based arguments. It lifted its prior stay, reversed the order, dissolved the injunction, remanded the case, dismissed pending motions as moot, and directed immediate issuance of the mandate.
Key Takeaways
- A Texas temporary-injunction order must itself explain the reasons for issuance, including why irreparable injury will result without relief.
- Oral findings at the injunction hearing cannot cure a written order that fails to satisfy Rule 683.
- An injunction that does not set the case for trial on the merits is subject to being declared void and dissolved.
Why It Matters
The decision underscores that Rule 683’s drafting requirements are mandatory, not technicalities that can be supplied by the hearing record. Parties obtaining temporary injunctive relief must ensure the signed order contains fact-based reasons for issuance and a trial setting.
The ruling addresses only the injunction’s procedural validity. It does not resolve the parties’ underlying dispute or determine whether SNAP could obtain a properly drafted injunction on remand.