In Castaneda v. Chapa, the executrix of an estate sued regarding the decedent changing account designations and a deed to real estate. No.13-22-00537-CV2024 Tex. App. LEXIS 3376 (Tex. App.—Corpus Christi May 16, 2024, no pet. history). The trial court ruled for the executrix, and the other parties appealed asserting that she did not have standing or capacity to sue and that the trial court did not have jurisdiction over the claims.

The court of appeals first held that the executrix had standing:

Pleading similar claims as trustee of Samuel’s trust, Wilma also sought to void TRS beneficiary designations made in 2015 and 2016, which divested Samuel of previously designated TRS annuity benefits. Wilma’s pleadings, therefore, identified the individuals personally aggrieved (the decedent’s estate and Samuel), alleged an injury (divestment of property and retirement assets) fairly traceable to unlawful conduct (fraud, breach of fiduciary duty, and conspiracy) by defendants (Thelma, Ninfa, and Eloy), and sought redress (declaratory judgment). Thus, we conclude Wilma has demonstrated standing.

Id. The court then found that appellants waived any complaint about capacity by failing to raise it below.

The court then discussed the trial court’s jurisdiction:

The jurisdiction of all Texas courts “derives from the Texas Constitution and state statutes.” County courts at law, specifically, “are creatures of statute with varying jurisdiction individually demarcated by the Legislature.” For example, unlike most Texas statutory county courts at law possessing limited concurrent jurisdiction with the district court, Nueces County courts at law hold “the jurisdiction provided by the constitution and by general law for district courts.”

However nuanced a jurisdictional analysis regarding statutory county courts at law may be, it is further complicated by probate jurisdiction, which “is, to say the least, somewhat complex.” “All probate proceedings must be filed and heard in a court exercising original probate jurisdiction.” In counties, such as Nueces County, where there exists no statutory probate court, the county court at law possesses original probate jurisdiction. A plaintiff’s claims must fall within the scope of a “probate proceeding” to invoke the original probate jurisdiction of a county court at law. Probate proceedings can include “an application, petition, motion or action regarding . . . an estate administration” and “any other matter related to the settlement, partition, or distribution of an estate.” The estates code further affords a statutory probate court and statutory county court at law exercising its probate jurisdiction with the ability to “exercise its pendent or ancillary jurisdiction over nonprobate matters when there is a close relationship between the probate and nonprobate claims and doing so will aid in the efficient administration of the estate.”

It is undisputed that this cause was filed in Nueces County Court at Law No. 2, a statutory county court at law, which possesses original probate jurisdiction. Further, neither party appears to dispute that Wilma’s pleading concerning the 2013 deeded transaction constituted an appropriate probate claim or that a probate proceeding was otherwise pending in probate court. At issue then is whether trial court has jurisdiction to hear Wilma’s TRS annuity claims concerning a nonprobate asset. Ninfa and Eloy argue that the TRS annuity claims do not exist in close relationship to Wilma’s probate claim, and therefore, the county court at law was without jurisdiction. We disagree that, for purposes of the county court at law’s subject matter jurisdiction, there must exist a nexus between Wilma’s probate and nonprobate claim.

…Here, the county court at law unequivocally possessed jurisdiction to hear both probate and nonprobate matters. While the estates code affords limited-in-jurisdiction statutory probate courts and statutory county courts at law additional jurisdiction over “pendent and ancillary jurisdiction as necessary to promote judicial efficiency and economy,” such provision neither limits nor substantively expands the county court at law’s jurisdiction here—which already possessed jurisdiction to hear both probate and nonprobate matters independent from the estates code. Assuming arguendo that the Nueces County Court at Law No. 2’s jurisdiction was predicated on the existence of an “ancillary or pendent” matter, Ninfa and Eloy’s argument would still fail. Although the TRS annuity is a nonprobate asset, the TRS annuity claims concern the same individual defendants (Ninfa, Eloy, and Thelma), same causes of action (fraud, breach of fiduciary duty, and conspiracy), and same underlying facts evidencing the decedent’s lack of capacity as Wilma’s probate claim. In other words, Wilma’s TRS annuity claims possess a sufficiently “close relationship” to Wilma’s probate claim so as to warrant the trial court’s exercise of its ancillary jurisdiction as necessary to promote judicial efficiency and economy. We overrule appellant’s first issue.

Id. After discussing some administrative law issues, the court affirmed the trial court’s judgment for the executrix.