In In re Est. of Ledbetter, Lonnie Ledbetter Jr., a wealthy individual with significant assets held in trusts originally structured to benefit his children, married Tawni Jones-Ledbetter at age 81 after his wife’s death. No. 02-25-00326-CV, 2026 Tex. App. LEXIS 1168 (Tex. App.—Fort Worth February 5, 2026, no pet.). During their 16-month marriage, Tawni controlled Lonnie’s finances, received millions in assets, and Lonnie executed new wills and trust documents disinheriting his children and appointing Tawni as successor trustee. The record indicated that Tawni demonstrated a pattern of dishonesty, including repeatedly lying under oath about her background, education, and identity, and invoking the USCS Const. Amend. 5 when questioned about her identity. Evidence showed that Tawni used trust assets for large purchases, such as a jet, a yacht, and a mansion in another state, and transferred multimillion-dollar properties to her personal trust.
After Lonnie’s death, his children filed suit to challenge the new wills and trust documents and sought temporary orders to prevent Tawni from dissipating assets. The trial court initially enjoined Tawni from controlling certain assets and, on its own motion, appointed a receiver to manage the trust assets to preserve them during litigation. The trial court’s decision to appoint a receiver was based on findings that Tawni posed a threat of irreparable dissipation of assets, was unlikely to comply with lesser remedies due to her dishonesty and evasiveness, and that the court could not realistically micromanage the complex assets.
The receivership order extended to all assets of Lonnie’s trusts and Tawni’s trust. The trial court acted under Texas Civil Practice and Remedies Code Section 64.001(a)(7) and Texas Rule of Civil Procedure 695, finding that the plain language of Rule 695 did not require an application for appointment of a receiver over fixed and immovable property.
The court of appeals noted:
Under Section 64.001(a)(7) of the Texas Civil Practice and Remedies Code, a trial court “may appoint a receiver . . . in any . . . case in which a receiver may be appointed under the rules of equity.” Generally, a receiver may be appointed under the rules of equity “when it is necessary to preserve the subject matter of the litigation during the pendency of the suit.” And when the facts before the trial court justify such an equitable receivership, the trial court may make the appointment on its own motion.
Id.
The court of appeals affirmed the trial court’s receivership order, holding that the trial court did not abuse its discretion and that the extraordinary facts of the case warranted a receivership under the rules of equity. The court of appeals justified the receivership by evidence of Tawni’s dishonesty under oath, invocation of the Fifth Amendment rights regarding her identity, history of financial impropriety (including prior bankruptcy and unauthorized asset transfers), and the risk of irreparable dissipation of trust assets.
Tawni challenged the trial court’s authority to appoint a receiver under the “rules of equity” provision, arguing that other specific statutory provisions should control and that an application was required for receivership over fixed property. The appellate court rejected these arguments, holding that Section 64.001(a)(7) provided sufficient authority and that Rule 695’s language did not preclude a sua sponte appointment:
Section 64.001(a) identifies certain circumstances in which a receivership is authorized. See id. § 64.001(a). It enumerates several types of receivership-warranting cases—e.g., “in an action between partners or others jointly owning or interested in any property or fund”—and it ends with a catch-all provision authorizing a receiver “in any other case in which a receiver may be appointed under the rules of equity.” Tawni argues that these subsections are mutually exclusive, meaning that a receiver may not be appointed “under the rules of equity” if the case is one of the receivership-warranting legal actions enumerated elsewhere in Section 64.001(a). And according to Tawni, this case was an “action between partners or others jointly owning or interested in any property or fund,” thus precluding the trial court from relying on “the rules of equity” catch-all provision. Yet, in the same breath, Tawni undercuts her own argument. To avoid endorsing the “joint[] own[ership]” provision as statutory authorization for the trial court’s receivership order, she argues that, although the “joint[] owne[rship]” provision applied enough to preclude the trial court from relying on the “rules of equity” alternative, it did not authorize the receivership because this case was not “an action between partners or others jointly owning or interested in any property or fund.” In other words, Tawni tries to have her cake and eat it, too. This she cannot do.If we adopt Tawni’s interpretation of Section 64.001(a) and treat the subsections as mutually exclusive, then the substance of Tawni’s argument renders her interpretation irrelevant because, by her own account, no other receivership-authorizing subsection applies, so the trial court was not precluded from relying on the “rules of equity” provision. But if we reject Tawni’s interpretation of the statute, then the issue ends there, as the trial court was free to rely on the “rules of equity” provision whether or not one of the other subsections applied. See id. Either way, Tawni’s challenge to the trial court’s reliance on Section 64.001(a)(7)’s “rules of equity” provision fails.
Id.
The receivership order was affirmed on appeal, with the court concluding that the extraordinary circumstances and evidence of risk to the assets justified the trial court’s actions under the rules of equity and applicable statutes.
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