In Ramirez v. Rodriguez, three co-trustees sued a fourth trustee to have him removed due to his hostile actions: he “has engaged in a pattern of creating hostility and friction that impedes and/or affects the operations of the trust.” No. 04-19-00618-CV, 2020 Tex. App. LEXIS 1340 (Tex. App.—San Antonio Feb. 19, 2020, no pet.). The defendant filed a motion to dismiss the suit, and the court of appeals affirmed the denial of the dismissal.