H. William Osterhout v. Eric Osterhout and Jeff Osterhout

CourtCourt of Appeals of Texas
DecidedAugust 12, 2025
Docket01-23-00600-CV
StatusPublished

This text of H. William Osterhout v. Eric Osterhout and Jeff Osterhout (H. William Osterhout v. Eric Osterhout and Jeff Osterhout) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
H. William Osterhout v. Eric Osterhout and Jeff Osterhout, (Tex. Ct. App. 2025).

Opinion

Opinion issued August 12, 2025

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-23-00600-CV ——————————— IN THE ESTATE OF SUZANNE JOYCE RYTHER, Deceased

On Appeal from Probate Court No. 1 Harris County, Texas Trial Court Case No. 490,834

MEMORANDUM OPINION

Appellant, H. William Osterhout (“William”), challenges the trial court’s final

judgment, entered after a jury trial and a bench trial on attorney’s fees, which

admitted the last will and testament of Suzanne Joyce Ryther, deceased (the

“decedent”), to probate and declined to award William attorney’s fees. In his sole

issue, William contends that the trial court erred in not awarding him attorney’s fees. We affirm.

Background

Appellee, Eric A. Osterhout (“Eric”), filed an application to probate the July

13, 2017 will of the decedent, his mother. Eric alleged that the decedent passed

away on December 21, 2020 at eighty-eight years old in Harris County, Texas. The

decedent’s husband had preceded her in death. The decedent had three biological

children, Eric, William, and appellee, Jeffrey Osterhout (“Jeffrey”), and two

stepchildren, Fenley Ryther, III (“Fenley”) and Carol Ann Johnson (“Carol Ann”).

Eric attached a copy of the decedent’s July 13, 2017 will to his application.

The will stated that the decedent “intend[ed] to give the entirety of [her] estate” to:

Eric, Jeffrey, Fenley, and Carol Ann. It also stated that the decedent “intend[ed] to

make no provisions in th[e] [w]ill for [William], and he [was] familiar with the

reasons.” (Emphasis omitted.) Thus, “all references” in the decedent’s will to her

“beneficiaries” were to Eric, Jeffrey, Fenley, and Carol Ann and did not include

William. (Internal quotations omitted.) The will was signed by the decedent and

two witnesses.

William filed a petition contesting Eric’s application to probate the decedent’s

July 13, 2017 will. In his second amended petition, William alleged that the July

31, 2017 will did not “reflect [the] [d]ecedent’s true testamentary intent,” the

decedent’s “non-probate designations and/or other purported changes to [her] bank

2 or financial accounts . . . d[id] not reflect [the] [d]ecedent’s true contractual intent,”

the July 13, 2017 will and “other non-probate transfers and/or designations [were]

the result of” Eric and Jeffrey’s “exertion of undue influence on [the] [d]ecedent

during a time when [her] cognitive abilities and physical condition were significantly

diminished,” and the decedent “lacked the requisite testamentary and/or contractual

capacity to make changes to her probate and non-probate estates.”

According to William, the decedent’s estate was worth $1,500,000, including

“over $400,000” in an individual retirement account (“IRA”). However, he believed

that the decedent’s “cognitive abilities had been significantly impaired at the time of

the execution” of her July 13, 2017 will and her 2017 IRA beneficiary designation.

William alleged that he “first noticed [the decedent’s] confusion and forgetfulness

in 2016.”

In William’s opinion, the decedent “would have never cut [him] out of her

estate,” and Eric and Jeffrey “were involved in the making of” the July 13, 2017

will. William also asserted that the decedent’s IRA designation, executed on May

14, 2017, was unduly influenced by Eric and Jeffrey so that William would be

excluded as a beneficiary. According to William, he had received nothing from the

decedent’s estate.

3 William requested declaratory relief, seeking declarations that the decedent’s

July 13, 2017 will and non-probate designations were invalid. Specifically, William

requested declarations that:

1. The decedent “did not have sufficient mental ability to understand the business of making a [w]ill, the effect of her act in so making a [w]ill, and the general nature and extent of her property”;

2. The decedent “did not have the mental capacity to know the object of her bounty, her next of kin, or their claims upon her. She did not have sufficient memory to collect in her mind the elements of the business to be transacted and to hold them long enough to perceive, at least, their obvious relation to each other and to be able to form a reasonable judgment as to them”;

3. The decedent “lacked the testamentary capacity required by law to make a valid” will.

4. “At the time of the execution of the [July 13, 2017 will], [the] [d]ecedent was ill. Her cognitive abilities were diminished, and she was dominated by Jeff[rey] and/or Eric in many of her activities and decisions”;

5. “At the time of the execution of the alleged non-probate designation(s) and/or contracts after January 2017, [the] [d]ecedent was ill. Her cognitive abilities were diminished, and she was dominated by Jeff[rey] and/or Eric in many of her activities and decisions.”

6. The decedent “was unduly influenced to execute or sign the [July 13, 2017 will] and/or non-probate designation(s)/contract(s) after January 2017 by Jeff[rey] and/or Eric’s compulsion, arguments, and/or deception. Jeff[rey] and/or Eric, allowing his mind to substitute for [the] [d]ecedent’s own, made the [July 13, 2017 will] and/or non-probate designation(s)/contract(s) without the [d]ecedent assenting to them or their terms”;

4 7. “[T]he beneficiary designation(s), specifically the T. Rowe Price IRA designation form, and/or other transfers in [the] [d]ecedent’s non-probate financial accounts and/or assets were and are invalid due to [the] [d]ecedent’s lack of contractual capacity”;

8. “There exists a constructive trust around all monies, funds or other assets stemming from [the] [d]ecedent’s non-probate financial accounts and/or her other real property”;

9. The decedent’s “non-probate monies, real property and assets be distributed in accordance with the laws of the [S]tate of Texas”; and

10. The July 13, 2017 will was “invalid and ineffective.”

William requested attorney’s fees under the Texas Uniform Declaratory Judgments

Act (the “DJA”)1 and the Texas Estates Code.2

A jury trial began on October 3, 2022 on Eric’s application to probate the

decedent’s July 13, 2017 will and William’s will contest.3 Before the jury trial

began, the parties agreed, related to the issue of attorney’s fees, that “the question of

1 See TEX. CIV. PRAC. & REM. CODE ANN. § 37.009 (“In any proceeding under this chapter, the court may award costs and reasonable and necessary attorney’s fees as are equitable and just.”). 2 See TEX. EST. CODE ANN. § 352.052(c) (“An interested person who, in good faith and with just cause, successfully prosecutes a proceeding to contest the validity of a will or alleged will offered for or admitted to probate may be allowed out of the estate the person’s necessary expenses and disbursements in that proceeding, including reasonable attorney’s fees.”). On appeal, William does not assert that he was entitled to attorney’s fees under the Texas Estates Code. 3 William did not provide this Court with a reporter’s record from the jury trial. The jury trial ended on October 12, 2022. We note that Eric and Jeffrey, in their briefing, raise the issue of a partial reporter’s record and its effect on William’s appeal, but due to our disposition below, we need not address this issue. See TEX. R. APP. P. 47.1; see also TEX. R. APP. P. 34.6(c).

5 ‘good faith’ and ‘just cause’ . . . for purposes of Tex[as] Estates Code [section]

352.052” would be submitted to the jury, but “the amount of attorney[’s] fees, court

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H. William Osterhout v. Eric Osterhout and Jeff Osterhout, Counsel Stack Legal Research, https://law.counselstack.com/opinion/h-william-osterhout-v-eric-osterhout-and-jeff-osterhout-texapp-2025.