In Harris v. Taylor, Harris challenged a probate court’s interlocutory order appointing a temporary administrator and a temporary injunction order enjoining her from accessing certain financial accounts. No. 01-15-00925-CV, 2016 Tex. App. LEXIS 8110 (Tex. App.—Houston [1st Dist.] July 28, 2016, no pet. history). Taylor alleged that Harris had entered into joint accounts with rights of survivorship with their father at a time when the father was mentally incompetent, and therefore, Taylor alleged that Harris should not be named executor and sought an injunction precluding Harris from withdrawing funds from the accounts. The trial court entered an order that appointed a temporary administrator and granted the injunction, and Harris appealed.

The court of appeals dismissed the appeal from the order appointing a temporary administrator because that order was an interlocutory order from which there was no right of appeal. Regarding the temporary injunction, the court reversed that order because the order did not set the matter for trial. Texas Rule of Civil Procedure 683 requires that every temporary injunction order shall include an order setting the matter or trial on the merits. The court held that requirement was mandatory, and any order that omitted that requirement was subject to being declared void and dissolved. Accordingly, the court reversed the injunction order.