Full Opinion

NUMBER 13-26-00470-CV COURT OF APPEALS THIRTEENTH DISTRICT OF TEXAS CORPUS CHRISTI – EDINBURG AMBER NICOLE PEREZ, Appellant, v. SURVIVORS NETWORK OF THOSE ABUSED BY PRIESTS (SNAP), INC, Appellee. ON APPEAL FROM THE 135TH DISTRICT COURT OF VICTORIA COUNTY, TEXAS MEMORANDUM OPINION Before Justices Peña, West, and Fonseca Memorandum Opinion by Justice Peña Appellant Amber Nicole Perez appeals from the trial court’s order granting appellee Survivors Network of Those Abused by Priests (SNAP), Inc.’s request for a temporary injunction signed on June 8, 2026. See TEX. CIV. PRAC. & REM. CODE § 51.014(a)(4). The order enjoins Perez from using or posting on social media any of SNAP’s confidential information and directs Perez to remove several Facebook posts concerning SNAP. Perez has not complied with the trial court’s order and SNAP has filed several motions during the pendency of this appeal seeking enforcement. 1 Among her six issues, Perez argues the trial court’s temporary injunction order is void for failure to comply with Rule 683. We agree and reverse the trial court’s order, dissolve the temporary injunction, and remand the cause to the trial court. 2 Under Texas Rule of Civil Procedure 683, “[e]very order granting an injunction . . . shall set forth the reasons for its issuance” and “set[] the cause for trial on the merits.” TEX. R. CIV. P. 683. A temporary injunction which does not strictly comply with Rule 683’s requirements “is subject to being declared void and dissolved.” Qwest Commc’ns Corp. v. AT & T Corp., 24 S.W.3d 334, 337 (Tex. 2000) (per curiam). “[A]ppellate courts do not have jurisdiction to address the merits of appeals from void orders; rather, they have jurisdiction only to determine that the order or judgment underlying the appeal is void and make appropriate orders based on that determination.” Freedom Commc’ns, Inc. v. Coronado, 372 S.W.3d 621, 623 (Tex. 2012) (per curiam); see Tatum v. Wells Fargo Home Mortg., Inc., No. 01-13-00855-CV, 2014 WL 7474074, at *12 (Tex. App.—Houston [1st Dist.] Dec. 30, 2014, no pet.) (mem. op.) (holding court lacked jurisdiction to reach merits-based arguments challenging temporary injunction order because order was void for non-compliance with Rule 683). Even if not raised by the parties, appellate courts “may sua sponte declare a temporary injunction order void if 1 On June 12, 2026, we granted Perez’s motion to stay the trial court proceedings. See TEX. R. APP. P. 29.3. 2 Because this issue is dispositive, we do not address Perez’s remaining arguments. See TEX. R. APP. P. 47.1. 2 it does not comply with Rule 683.” Clark v. Hastings Equity Partners, LLC, 651 S.W.3d 359, 370 n.8 (Tex. App.—Houston [1st Dist.] 2022, no pet.) (citing City of Sherman v. Eiras, 157 S.W.3d 931, 931 (Tex. App.—Dallas 2005, no pet.)); EOG Res., Inc. v. Gutierrez, 75 S.W.3d 50, 53 (Tex. App.—San Antonio 2002, no pet.) (holding failure to comply with Rule 683 renders a temporary injunction order “fatally defective and void, whether specifically raised by point of error or not”). Here, the temporary injunction order fails to “set forth the reasons the trial court believes irreparable injury will result absent the granting of an injunction” or reference any facts on which the trial court relied on to reach its conclusion. Hoist Liftruck Mfg., Inc. v. Carruth-Doggett, Inc., 485 S.W.3d 120, 123 (Tex. App.—Houston [14th Dist.] 2016, no pet.) (holding temporary injunction order that did not state the reason for issuance or address why irreparable injury would result absent injunction was void for failure to comply with Rule 683); see TEX. R. CIV. P. 683; Good Shepherd Hosp., Inc. v. Select Specialty Hosp.-Longview, Inc., 563 S.W.3d 923, 928–29 (Tex. App.—Texarkana 2018, no pet.). SNAP responds that the trial court orally pronounced at the temporary injunction hearing that SNAP had demonstrated potential harm, but “mere recitals regarding harm are insufficient” and “the order itself must contain the reasons for its issuance.” In re Chaumette, 456 S.W.3d 299, 305 (Tex. App.—Houston [1st Dist.] 2014, orig. proceeding) (emphasis added). Moreover, the temporary injunction fails to set a trial date. See TEX. R. CIV. P. 683; In re Corcoran, 343 S.W.3d 268, 269 (Tex. App.—Houston [14th Dist.] 2011, orig. proceeding) (holding failure to contain trial date voided order); EOG Res., Inc., 75 S.W.3d at 53 (same). Because the temporary injunction signed on June 8, 2026, does not comply with 3 Rule 683, we conclude it is void. See Qwest Commc’ns, 24 S.W.3d at 337; Eiras, 157 S.W.3d at 931. We lift the stay we previously imposed in this case, reverse the trial court’s order, dissolve the temporary injunction, and remand the cause to the trial court for proceedings in accordance with this memorandum opinion. We dismiss any pending motions as moot. Furthermore, the Clerk of this Court is directed to issue the mandate immediately. See TEX. R. APP. P. 18.6. L. ARON PEÑA JR. Justice Delivered and filed on the 13th day of August, 2026. 4