In Archer v. Archer, the trust stated that: “We request that any questions or disputes that may arise during the administration of this trust be resolved by mediation and if necessary, arbitration in accordance with the Uniform Arbitration Act.” No. 05-13-013410-CV, 2014 Tex. App. LEXIS 6551 (Tex. App.—Dallas June 17, 2014). The beneficiaries sued the trustee for breach of fiduciary duty, and the trustee sought to compel arbitration, which the trial court denied. The defendant then appealed. The court of appeals held that it was clear that mandatory arbitration clauses in trust documents are enforceable. Id. (citing Rachal v. Reitz, 403 S.W.3d 840, 843 (Tex. 2013)). After reviewing the trust in whole, the court held that the provision was permissive and not mandatory and affirmed the trial court’s refusal to compel arbitration.