In the Estate of Mitchell Boyd Wilson v. .

Court of Appeals of Texas·Decided August 27, 2025·No. 04-24-00191-CV·Published

Opinion

Fourth Court of Appeals San Antonio, Texas OPINION

No. 04-24-00191-CV

IN THE ESTATE OF Mitchell Boyd WILSON, Deceased

From the County Court, Edwards County, Texas Trial Court No. 1171 Honorable Polly Jackson Spencer, Judge Presiding

Opinion by: H. Todd McCray, Justice

Sitting: Irene Rios, Justice Lori Massey Brissette, Justice H. Todd McCray, Justice

Delivered and Filed: August 27, 2025

AFFIRMED

This appeal arises from a summary judgment involving claims against the estate of Mitchell

Boyd Wilson by his surviving spouse, Tamara Wilson. Throughout the course of the underlying

probate proceeding, Tamara brought several actions against the Estate. The particular action giving

rise to this appeal is a suit seeking a determination of Tamara’s community property stake in the

Estate. The trial court granted summary judgment and awarded attorney’s fees in favor of the

Estate. Tamara appeals. We affirm the judgment of the trial court. 04-24-00191-CV

BACKGROUND

Mitchell Boyd Wilson died on May 4, 2021. At the time of his death, he was a shareholder,

director and employee of Rebel Contractors, Inc. The father of Wilson’s first wife started Rebel

and gifted shares of Rebel to Wilson in 1991. In 2002, Wilson married Tamara, and the marriage

was in effect at the time of his death. In 2006, Wilson’s son from his first marriage, Alex Wilson,

joined Rebel and worked there with his father until Wilson’s death. Alex is the executor of

Wilson’s estate. On July 6, 2021, Alex filed an application to probate Wilson’s will. The will

provided Tamara was to receive $1.00, with the remainder of the estate going to Alex and Wilson’s

other living children.

Tamara first appeared in the case via a plea in abatement on July 19, 2021. After that time,

she filed numerous other motions and pleadings, including a motion to dismiss for lack of

jurisdiction, a motion for rehearing, two applications for family allowance, a motion to transfer

venue, an opposition and request to amend the estate inventory, an opposition and contest to

probate Wilson’s will, and the pleading that is the impetus of this appeal: Original Petition-In-

Intervention for Declaratory Judgment. The latter was filed June 9, 2023.

By this pleading, Tamara sought a declaratory judgment that (1) Rebel's income, profits

and dividends are community property, (2) a ranch purchased and owned by Rebel is community

property, (3) the ranch’s income, profits, dividends and assets are community property and (4)

certain accounts allegedly owned by Wilson at the time of his death are community property.

Tamara also sought reimbursement to the community for unpaid labor stemming from her claim

that Wilson received inadequate compensation from Rebel for his time, toil, talent and effort while

the company was under his control. Tamara further claimed breach of fiduciary duty regarding

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Wilson’s handling of the community estate. Finally, Tamara sought partition of the community

estate, an accounting, and attorney’s fees.

From July 18, 2023, to November 3, 2023, the Estate filed five motions for partial summary

judgment. On July 10, 2024, Tamara responded to the motions for summary judgment and, by the

same response, moved to compel discovery and to continue the hearing in order to obtain

discovery. A hearing on the motions was set for January 17, 2024. The trial court ultimately denied

the motion for continuance, granted the Estate’s evidentiary objection, denied Tamara’s

evidentiary objection, and granted the motions for summary judgment. The parties agreed to try

the issue of attorney’s fees to the court by affidavit. The trial court subsequently severed this case

from the probate proceedings and issued a final judgment disposing of all issues raised by

Tamara’s pleadings.

SECURITY FOR COSTS

Tamara claims that the trial court erred in ordering her to pay security for costs. A court

has discretion to “require a person who files a pleading in a probate proceeding to provide security

for probable costs before the person is allowed to participate further.” TEX. ESTATES CODE ANN.

§ 53.052(b); see Ridge v Ridge, 658 S.W.3d 427, 437 (Tex. App. Houston [14th Dist.] 2022, no

pet.). In this case, the trial court ordered Tamara to pay $40,000 as security against the Estate’s

costs. The enforcement date of the court’s order was December 21, 2023. On December 8, 2023,

Tamara filed an affidavit of indigency, after which the deadline for security passed with no further

action taken on the order. On January 17, 2023, the court heard the Estate’s motions for summary

judgment and, subsequently, considered the issue of attorney’s fees, severed the case from the

probate proceedings and entered final judgment, all with no further action on the order for costs.

-3- 04-24-00191-CV

While failure to comply with a security for costs order could result in the dismissal of a

party’s claims under Texas Rule of Civil Procedure 143, if the court does not enforce the order, it

becomes procedurally inconsequential. See TEX. R. CIV. P. 143. Courts have explicitly dismissed

claims for failure to comply with a security order, demonstrating that enforcement is critical to the

order's legal effect. See Clanton v. Clark, 639 S.W.2d 929, 931 (1982); Ridge, 658 S.W.3d at 437.

It follows, then, that if the court does not dismiss claims or take other enforcement actions, the

order does not affect the outcome of the case and is not ripe for appellate review. Bridgeport

Independent School District v. Williams, 447 S.W.3d 911, 918 (2014) (concluding claims not ripe

because alleged injury remained contingent); Atmos Energy Corp. v. Abbott, 127 S.W.3d 852, 858

(2004) (finding claims not ripe because alleged controversy was speculative and there was no

showing of actual or imminent harm).

The order in this case was not collected upon nor made part of the final judgment. In fact,

no action at all was taken to enforce it. Tamara has not demonstrated how the unenforced order

created a justiciable controversy, affected the outcome of the proceedings or otherwise prejudiced

her in any way. Under these circumstances, we will not address the propriety of the trial court’s

order on security for costs as it does not present a justiciable controversy ripe for review.

MOTION FOR CONTINUANCE

Next, Tamara contends that the trial court erred in denying her motion for continuance

pursuant to Texas Rule of Civil Procedure 166a(g). Tamara claims that her motion for continuance

should have been granted because the Estate failed to provide discovery that was necessary to

Tamara’s opposition to the motions for summary judgment and because the discovery period was

still in its infancy when her motion for continuance was heard on January 17, 2024. Specifically,

Tamara claims that the discovery period began with her June 9, 2023, petition asserting community

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property claims, and did not end until June 17, 2024. Alternatively, the Estate claims that the

discovery period ended on December 23, 2022, following Tamara’s first appearance in the probate

case via her plea in abatement.

Texas appellate courts have declined to read such a technical time requirement into Rule

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