Hill v. Hunt et al

Memorandum Opinion and Order – Page 1
IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
ALBERT G. HILL, III, individually
and as a Beneficiary of the Margaret
Hunt Trust Estate, derivatively on
behalf of the Margaret Hunt Trust
Estate, individually as a Beneficiary of
the Haroldson Lafayette Hunt, Jr.
Estate, and derivatively on behalf of the
Haroldson Lafayette Hunt, Jr. Estate,
§
§
§
§
§
§
§
§
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Plaintiff, 	§
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v. 	§ 	Civil Action No. 3:07-cv-2020-L
§
WILLIAM SCHILLING, et al., 	§
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Defendants. 	§
MEMORANDUM OPINION AND ORDER
Before the court is the Motion to Enforce Final Judgment and Settlement Agreement and
Application for Temporary Restraining Order, Preliminary Injunction and Permanent Injunction
(Doc. 2055) (“Motion”), filed on December 23, 2025, by Margaret Keliher (as Independent
Executor of the Estate of Albert G. Hill, Jr., Deceased) and Carol E. Irwin (as Independent
Executor of the Estate of Ivan Irwin, Jr., Deceased, and Former Co-Trustee of the Lyda-Hunt–
Margaret Trust f/b/o Albert Galatyn Hill, Jr.) (collectively, “Movants”). Having carefully
considered the Motion, brief in support (Doc. 2056), response and brief in support (Doc. 2062),
reply (Doc. 2060), appendixes, record, and applicable law, the court denies the Motion in its
entirety.
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I. 	Factual Background and Procedural History
This seemingly interminable family dispute relates to “the management of two trusts
created by the late Texas oil magnate H.L. Hunt.” Hill v. Schilling, 495 F. App’x 480, 482 (5th
Cir. 2012).1 “H.L. Hunt established the trusts at issue—the Margaret Hunt Trust Estate (‘MHTE’)
and the H.L. Hunt, Jr. Trust Estate (‘HHTE’)—in the names of his two eldest children.” Id.
Margaret Hunt had three children, including Albert G. Hill, Jr. (“Hill Jr.” or “Al Jr.”), all of whom
were beneficiaries of both the MHTE and HHTE. Hill Jr. in turn also had three children—one of
whom is Albert G. Hill, III (“Hill III”). Hill III also has three children—Albert Hill, IV; Nance
Hill; and Caroline M. Hill (collectively, the “Grandchildren”). Hill III initiated the instant litigation
in Texas state court in December 2007, alleging various forms of wrongdoing by Hill Jr. and others
in the management of the MHTE and HHTE, and seeking, inter alia, a declaration that he was a
direct and vested beneficiary of the MHTE.
Movants request the court to intervene in a probate court proceeding related to a separate
trust created under the 1954 Last Will and Testament of Lyda Bunker Hunt, who died in 1955.
That trust, the Lyda Hunt–Margaret Trust f/b/o Albert Galatyn Hill, Jr. (“Lyda Hunt–Margaret
Trust”), is the subject of a lawsuit brought by Caroline Hill in Probate Court No. 2 of Dallas
County, Texas (the “State Probate Case”).2 In that case, Caroline Hill seeks an accounting and
alleges that Hill Jr. and his co-trustees, between 2014 and 2017, “looted the [Lyda Hunt–Margaret
Trust] and dissolved it, leaving nothing for the Grandchildren[,]” whom Hill Jr. had previously
1 As described by the Fifth Circuit, H.L. Hunt is “the late Texas oil baron reputed to be one of the world’s
richest men when he died in 1974.” Hill v. Washburne, 953 F.3d 296, 300-01 (5th Cir. 2020) (citations
omitted).
2 Cause No. PR-25-02919-2, Caroline M. Hill v. Margaret Keliher (as Independent Executor of the Estate
of Albert G. Hill, Jr., Deceased), Carol E. Irwin (as Independent Executor of the Estate of Ivan Irwin, Jr.,
Deceased), Joyce E. Waller (as Co-Trustees of the Lyda Hunt-Margaret Trusts f/b/o Albert G. Hill, Jr.),
and Galatyn Finance, LLC, Probate Court No. 2, Dallas County, Texas.
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Memorandum Opinion and Order – Page 3
appointed as contingent beneficiaries of the Lyda Hunt–Margaret Trust, thereby entitling them to
receive, upon Hill Jr.’s death, Hill Jr.’s “periodic interest income as well as an interest in the Lyda
Hunt–Margaret Trust’s corpus upon its eventual termination.” Doc. 2057 at 20 (Caroline Hill’s
Orig. Pet. ¶ 2); id. at 26 (Caroline Hill’s Orig. Pet. ¶ 31).
Movants seek to enjoin Caroline Hill from proceeding with the State Probate Case. They
contend that Caroline Hill is breaching the May 13, 2010 Global Settlement and Mutual Release
Agreement (the “GSA”) (Doc. 879) that settled this action and the November 8, 2010 Final
Judgment (the “Final Judgment”), issued by United States District Judge Reed C. O’Connor (the
presiding judge at the time), in which he implemented and memorialized the GSA. See Final J. ¶
1 (Doc. 999).
Although the history of the underlying dispute between Hill III and Hill Jr. is beyond the
scope of this opinion, to resolve the pending Motion, the court must revisit, yet again, certain
aspects of Hill III’s dispute with Hill Jr. and others as well as its prior opinions. The court will
limit its recitation of the background facts to those necessary to rule on the pending Motion.3
A. The Underlying Lawsuit
On June 14, 2007, Margaret Hunt Hill died and her equitable interest in the MHTE passed
in equal shares to her three children—Hill Jr., Lyda Hill, and Alinda Hill Wickert—subject to any
disclaimers. Doc. 212-2 at 10, ¶¶ 18, 19. In December 2007, Hill III brought a lawsuit in Texas
state court in his individual capacity and on behalf of the MHTE and HHTE against specific
beneficiaries of the MHTE and HHTE, including Hill Jr., Hill Jr.’s siblings, and the trustees and
3 The court’s recitation of the relevant background is based on the materials contained in the appendixes
submitted by the parties in support of their legal briefs, the court’s prior decisions in this case, and the
copious record (including over 2060 separate docket entries).
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members of the advisory boards of the MHTE and HHTE. Among other things, Hill III alleged
wrongdoing in the management and administration of the MHTE and HHTE by their respective
trustees and violations of the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18
U.S.C § 1961, et seq. A primary focus of the lawsuit was Hill III’s claim to be a current beneficiary
of the MHTE pursuant to Hill Jr.’s 2005 Disclaimer.4 Following removal to federal court on
December 3, 2007, the case was randomly assigned to Judge O’Connor.
1. 	The GSA
Ultimately, Hill III agreed to a settlement of the dispute. On May 13, 2010, the parties
entered into the GSA (Doc. 879) that settled this action and related state court actions. See
generally Hill v. Schilling, 495 F. App’x at 482-83 (describing the genesis of the GSA). In the
GSA, pursuant to a Waiver of Standing clause, each party agreed to waive his or her standing and
right to demand information, seek accountings, or assert any claim or cause of action in connection
with any trust “for the primary benefit of a descendant of Margaret Hunt Hill” of which he or she
was not a current beneficiary. Doc. 879 at 21, § III ¶ 5(b) (the “Waiver of Standing Clause”).
As recently summarized by the Fifth Circuit:
In exchange for a nine-figure payment and other benefits, Hill III agreed
“not to contest the Last Will and Testament of Al Jr. or file any additional action,
lawsuit, or legal proceeding challenging the disposition of his property” (the no-
contest 	clause). 	The 	parties 	further 	“agree[d] 	that 	the 	remedy 	of 	specific
performance and/or injunctive relief (whether mandatory or by restraint) shall be
4 In 2005, Hill Jr. signed an irrevocable disclaimer of a portion of his interest in the MHTE in favor of his
three children, including Hill III. See Doc. 879 (GSA at Ex. C, 2005 Disclaimer). The effect of the
disclaimer is that Hill Jr.’s disclaimed interest passed to Hill III and his two siblings after Margaret Hunt
Hill’s death. See Doc. 611 (March 4, 2010 Mem. Op. & Order 7-8). In 2007, Hill Jr. sought to rescind his
2005 disclaimer, along with another partial disclaimer he had executed in 2007. This litigation ensued.
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Memorandum Opinion and Order – Page 5
available for the breach of any term, condition, covenant, or warranty of” the
settlement agreement. The parties consented to the district court’s continuing
jurisdiction over actions to enforce the settlement agreement.
Hill v. Washburne, 953 F.3d 296, 301 (5th Cir. 2020).5
2. 	The Final Judgment
On November 8, 2010, Judge O’Connor issued the Final Judgment implementing and
memorializing the parties’ GSA, which he incorporated by reference into the Final Judgment. Doc.
999. Consistent with the GSA, the Final Judgment declared Hill Jr.’s 2005 Disclaimer valid and
partitioned portions of the MHTE and the HHTE, as to which Hill Jr. did not disclaim any of his
equitable interests, into the Hill Jr. Trusts and, for Hill III’s benefit, his one-third interest in the
Disclaimed Beneficial Interests, because of the 2005 Disclaimer, were partitioned into the Hill III
Trusts.6 Doc. 999 at 6, ¶ 5; Doc. 999 at 12-13, ¶¶ 8.f.i and 8.f.ii; Doc. 999 at 20, ¶ 8.i; Doc. 999 at
22-23, ¶ 9.c.7 The Final Judgment provided that all of these trusts were governed by the 1935 Trust
Instruments establishing the MHTE and HHTE. Doc. 999 at 24-25, ¶ 14.
The Final Judgment enforced the agreeing parties’ Waiver of Standing Clause, as follows:
Waiver of Standing
28. IT IS ORDERED that, pursuant to the Agreement, the Court finds that
during such time as an Agreeing Party is not a current beneficiary of a trust for the
5 The Fifth Circuit also recognized in Hill v. Washburne, “After ‘protracted [and] complicated’ litigation,
Hill v. Schilling, 593 F. App’x 330, 331 (5th Cir. 2014), squabbling over the trusts was supposedly ended
by a settlement agreement confected in 2010. Yet, over the next four years, our court ‘weighed in on the
settlement’ four times. Id. This appeal makes it five.” Hill v. Washburne, 953 F.3d 296, 301 (5th Cir. 2020).
6 These trusts are (1) the MHTE – Albert G. Hill, III Trust, for the benefit of Hill III, and (2) the MHTE –
Albert G. Hill Jr. Income Beneficiary / Al III Termination Beneficiary Trust, for the benefit of Hill Jr.
during his lifetime and for the benefit of Hill III after Hill Jr.’s death and are referred to herein, collectively,
as the “Hill III Trusts.”
7 The Final Judgment also partitioned portions of the MHTE and HHTE into separate trusts for Lyda Hill,
who became the sole current beneficiary of separate one-third shares of the MHTE and HHTE. Doc. 999 at
7-9, ¶¶ 8.a, 9.a.
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Memorandum Opinion and Order – Page 6
primary benefit of a descendant of Margaret Hunt Hill (“MHH”) (an “MHH Trust”)
and any other descendant of MHH is living, such Agreeing Party has waived: (1)
his or her status as an interested person in such trust, and (2) all rights that he or she
may have as a future or contingent beneficiary of such trust under the instrument
establishing such MHH Trust, under applicable common law, or under applicable
state law, including but not limited to the right to demand information, seek an
accounting, or assert any claim or cause of action in connection with any such trust.
. . . IT IS FURTHER ORDERED that, pursuant to the Agreement, the waivers by
each Agreeing Party in this paragraph shall not apply to an MHH Trust during any
period in which such Agreeing Party is a current beneficiary of that MHH Trust,
although the waivers in this paragraph shall continue to apply to any actions taken
or omitted by any other person or entity during the period that such Agreeing Party
was not a current beneficiary. For purposes of this paragraph, “current beneficiary”
means a person who, at the time a current beneficiary is determined, is then entitled
to receive, or is then, in an exercise of discretion by the trustee of such trust, a
possible recipient of, income or principal of such trust.
Doc. 999 at 35-36, ¶ 28.
As part of the Final Judgment, the court, incorporating the No Contest Clause from the
GSA, ordered Hill III and Erin Hill (in all their capacities) and the Grandchildren not to contest
Hill Jr.’s will or challenge the disposition of his property:
IT IS ORDERED that Al III (in all capacities), Erin [Hill] (in all her capacities),
the Grandchildren, and all of their descendants and heirs shall not contest the Last
Will and Testament of Al Jr., or file any additional action, lawsuit, or legal
proceeding challenging the disposition of Al Jr.’s property.
Doc. 999 at 36, ¶ 29.
Finally, consistent with the GSA, Judge O’Connor retained continuing jurisdiction over the
implementation and enforcement of the Final Judgment:
IT IS ORDERED that, without affecting the finality of this Final Judgment,
the Court hereby retains continuing jurisdiction over the implementation of the
[Settlement] Agreement, the Final Judgment, and the Parties for purposes of
implementing and enforcing the [Settlement] Agreement and this Final Judgment.
IT IS FURTHER ORDERED that any controversy or claim arising after the date of
execution of the [Settlement] Agreement and arising out of the [Settlement]
Agreement or the Documentation shall be resolved by this Court. Each of the
Agreeing Parties agrees and covenants not to, and IT IS ORDERED that none of
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the Agreeing Parties shall, file or assert any of the released Claims (in law or in
equity).
Doc. 999 at 43, ¶ 45.8 On October 2, 2013, this matter was reassigned to the undersigned following
the recusal of Judge O’Connor (who had presided over the matter for approximately seven years),
which was followed by the recusals of Judges Lynn, Solis, Godbey, Boyle, Fitzwater, and
Kinkeade.
B. Hill Jr.’s Last Will and Testament
On December 20, 2014, Hill Jr. executed his Will, in which he exercised the testamentary
special powers of appointment (1) “under Article III, Section 3 of the HLHTE-Albert G. Hill, Jr.
Trust, created under a settlement agreement,” in favor of the “Al G. Hill, Jr. Charitable Lead
Annuity Trust” and (2) “under Article III, Section 3 of the MHTE-Albert G. Hill, Jr. Trust, created
under a settlement agreement” in favor of the “Al G. Hill, Jr. Charitable Lead Annuity Trust.” Hill
v. Schilling, 2018 WL 3239795, at *4-5 (N.D. Tex. July 3, 2018) (Lindsay, J.). As previously
noted, supra, these trusts were created under the GSA as part of the settlement of this dispute.
In addition, Hill Jr. exercised his testamentary powers of appointment over other family
trusts not related to the MHTE or HHTE, including the Lyda Hunt–Margaret Trust and the Albert
Hill Trust, as follows:
(a) I hereby exercise the testamentary special power of appointment given to me
under paragraph VIII, of The Lyda Hunt-Margaret Trusts, Al G. Hill, Jr., created
under the Last Will and Testament of Lyda Bunker Hunt, dated the 16th day of
September, 1954, in favor of my grandchildren [AGH, IV, NHH, and CMH], that
they should succeed me as to all interests which I have in such Trust estate; [and]
(b) I hereby exercise the power of appointment given to me under Article III,
Section 3 of the Albert Hill Trust, dated the 10th day of April, 1945, in favor of the
8 Hill III appealed the Final Judgment challenging, among other things, the addition of provisions that were
not part of the GSA. The Fifth Circuit affirmed the Final Judgment. See Hill v. Schilling, 495 F. App’x 480
(5th Cir. 2012) (consolidated appeal).
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Al G. Hill, Jr. Family Foundation ("Foundation"), so that the Foundation should
succeed me as to all interests which I have in such Trust estate[.]
Id. at *4 (original emphasis).
C. Termination of Trusts During Hill Jr.’s Lifetime
On or about December 13, 2016, the Trustees and the Advisory Board Members of the Hill
Jr. Trusts voluntarily dissolved the Hill Jr. Trusts. Id. at *5. Specifically, the MHTE - Albert G.
Hill, Jr. Trust was terminated pursuant to a written instrument titled MHTE - Albert G. Hill, Jr.
Trust Trustee Resolution and Record of Trust Termination and the HLHTE - Albert G. Hill, Jr.
Trust was terminated pursuant to a written instrument titled HLHTE - Albert G. Hill, Jr. Trust
Trustee Resolution and Record of Trust. Id.
In addition, on December 28, 2016, the Trustees and the Advisory Board Members
voluntarily dissolved the Lyda Hunt–Margaret Trust pursuant to a written instrument titled the
Lyda Hunt - Margaret Trusts, FBO Albert G. Hill, Jr. Record of Trust Termination. Id. Unlike the
Hill Jr. Trusts, supra, the Lyda Hunt–Margaret Trust was never mentioned in the GSA and not
incorporated into the Final Judgment. The court never supervised the Lyda Hunt–Margaret Trust
and never adjudicated any rights under it.
D. 	Hill Jr.’s Death and the Probate of His Will
On December 6, 2017, counsel for Hill III filed a Suggestion of Death, stating, “upon the
record, pursuant to Rule 25(a)(1) of the Federal Rules of Civil Procedure, the death of [Hill Jr.],
Defendant, on December 2, 2017.” Suggestion of Death (Doc. 1811). On December 7, 2017, Tyree
Miller (“Miller”), named the Independent Executor of Hill Jr.’s Estate by his will, filed an
Application for Probate of Will and Issuance of Letters Testamentary in Probate Court No. 2 of
Dallas County, Texas (the “Hill Jr. Probate Proceeding”), seeking to probate Hill Jr.’s will, to be
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appointed as the independent Executor of Hill Jr.’s Estate, and to have letters testamentary issued
in accordance with the will. Id.
Hill III filed an Original Answer in the Hill Jr. Probate Proceeding, asserting, among other
things, that Miller should be disqualified because of a conflict of interest and (1) claiming and
seeking a declaration that Hill Jr. did not have the powers of appointment he exercised in his Will;
(2) seeking accountings of certain trusts; (3) seeking injunctive relief; (4) seeking the imposition
of constructive trusts; and (5) seeking damages and attorney’s fees. Id.
E. 	Hill III’s Sisters’ and Hill III’s Respective Motions Seeking to Enforce the GSA
and Final Judgment
On May 29, 2018, Heather Hill Washburne (“Washburne”) and Elisa Hill Summers
(“Summers”)—Hill, III’s sisters—filed a motion seeking to enjoin Hill III in the Hill Jr. Probate
Proceeding from (1) contesting Hill Jr.’s Will and challenging the disposition of Hill Jr.’s property
in violation of the No Contest Clause, and (2) violating the GSA and the Final Judgment by
asserting claims concerning the Hill Jr. Trusts because he was not a current beneficiary. See Doc.
1876.
Also, on May 29, 2018, Hill III filed his own motion to enforce the GSA and Final
Judgment, contending that the Hill Jr. Trusts that were supposed to be preserved by the Final
Judgment had been prematurely and unlawfully terminated by Hill Jr. and others, thereby
destroying the valuable inheritance of Hill III and his descendants, from the H.L. Hunt family,
estimated to be worth in excess of $1 billion. See Doc. 1877. Hill III challenged both Hill Jr.’s
exercise of his powers of appointment in his Will in 2014 and the subsequent dissolution of the
Hill Jr. Trusts in 2016. Id. He also challenged the dissolution of the Lyda Hunt–Margaret Trust.
Id. Hill III sought an injunction to preserve the assets of the Hill Jr. Trusts as well as the Lyda
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Hunt–Margaret Trust and to prevent dissipation, concealment, and further transfer of such assets,
and preservation of all records relating to such trusts and actions affecting them. Id.
F. 	The Court’s July 3, 2018 Decision Declining to Extend its Continuing Jurisdiction
Beyond the MHTE and HHTE—the Trusts at Issue in the Underlying Litigation
On July 3, 2018, the court denied the requests for injunctive relief of both parties without
prejudice, holding any relief would be “premature” because of the pending severed probate
proceedings, in which the parties were litigating the same issues. Hill, 2018 WL 3239795, at *11.9
Further, as to any trusts other than the MHTE–Albert G. Hill, Jr. Trust and the HLHTE–Albert G.
Hill, Jr. Trust, both created as part of the GSA and incorporated into the Final Judgment, the
undersigned defined the scope of the court’s continuing jurisdiction:
As a threshold matter, the court notes that the Settlement Agreement and
Final Judgment only modified the MHTE and HHTE. In the Final Judgment, Judge
O’Connor 	retained 	“continuing jurisdiction 	over 	the implementation of 	the
[Settlement] Agreement, the Final Judgment, and the Parties for purposes of
implementing and enforcing the [Settlement] Agreement and this Final Judgment.”
See Final J. ¶ 45 (Doc. 999). He further ordered that “any controversy or claim
arising after the date of execution of the [Settlement] Agreement and arising out of
the [Settlement]Agreement or the Documentation shall be resolved by this Court.”
Id. With respect to any Hunt/Hill family trusts other than the MHTE and HHTE,
therefore, this court does not have continuing jurisdiction, and issues pertaining to
9 On September 12, 2018, Washburne and Summers filed another Emergency Motion to Enforce the Final
Judgment and Settlement Agreement, and Application for Temporary Restraining Order, Preliminary
Injunction, and Permanent Injunction after Hill III took additional actions in the Hill Jr. Probate Proceeding
challenging Hill Jr.’s Will and the disposition of his property. Doc. 1884. On December 7, 2018, the court
granted the motion and request for injunctive relief, finding that Hill III’s challenge to Hill Jr.’s Will and
to the appointment of Keliher, as Independent Executor of Hill Jr.’s Estate, as well as his appeal of Judge
Ingrid M. Warren’s October 11, 2018 Will Contest Order and Order Admitting Will to Probate, violated
the broad waiver he had agreed to in section III(1)(f) of the GSA and paragraph 29 of the Final Judgment,
intentionally relinquishing his known right to contest Hill Jr.’s Will or challenge the disposition of his
property in exchange for valuable consideration. Doc. 1919. Hill III appealed. Doc. 1925. The Fifth Circuit
affirmed the “future-looking terms of the injunction: its prohibition on contesting Hill Jr.’s will in any
manner, in any court; and its prohibition on filing, pursuing, or prosecuting any action . . . that violates the
terms of the Settlement Agreement or Final Judgment.” Hill v. Washburne, 953 F.3d 296, 310 (5th Cir.
2020) (internal quotation marks omitted). The Fifth Circuit dismissed as moot the remainder of Hill III’s
appeal because “in the interim, the Texas appeals court [] lost its jurisdiction over Hill III’s state appeal,”
and Hill III withdrew his “failed will challenges in the probate court.” Id. at 301.
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those family trusts are not properly before this court. The court declines to expand
its continuing jurisdiction beyond the implementation and enforcement of the
Settlement Agreement and Final Judgment.
Id. at 7 (emphasis in original).
Otherwise stated, the court limited its retention of continuing jurisdiction stemming from
the Final Judgment to those trusts arising from the GSA and related to the MHTE and HHTE,
which are the subject of the underlying litigation. Perforce, the court’s continuing jurisdiction does
not extend as far as other trusts, such as the Lyda Hunt–Margaret Trust (and trusts created under
separate instruments), and the exercise of ancillary jurisdiction to enforce the Final Judgment is
not warranted here. Notably, no party or participant/intervenor in this matter challenged the
court’s limited retention of jurisdiction or appealed the decision.
G. Movants’ Challenge to Caroline Hill’s State Probate Suit Concerning the Lyda
Hunt–Margaret Trust as a Violation of the GSA and Final Judgment and Request
for Injunctive Relief
On September 5, 2025, Caroline Hill filed an Original Petition and Jury Demand in the
State Probate Case, alleging misconduct relating to the Lyda Hunt–Margaret Trust, and demanding
an accounting and attorney’s fees from the prior co-trustees and the executor of Hill Jr.’s Will.
With leave of court, on December 23, 2025, Movants filed their Motion, contending that
Caroline Hill, by seeking an accounting of the Lyda Hunt–Margaret Trust, “is violating the Waiver
of Standing Clause in the [GSA] and Final Judgment which prevents her from seeking an
accounting or asserting claims about a trust of which she is not a current beneficiary.” Doc. 2056
at 5. Specifically, Movants assert that the Lyda Hunt–Margaret Trust
was a trust for the primary benefit of Al Jr., a descendant of Margaret Hunt Hill.
Caroline was a “contingent beneficiary” of the [Lyda Hunt–Margaret Trust]. She
never became a “current beneficiary” because the [Lyda Hunt–Margaret Trust] was
terminated in 2016, approximately one year before Al Jr.’s death. As a result,
Caroline is breaching the [GSA] and violating the Final Judgment with her Lawsuit.
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Id. Movants ask the court to enforce its Final Judgment and the GSA, and they seek a temporary
restraining order, as well as preliminary and permanent injunctive relief:
• 	enjoining Caroline (together with her attorneys, representatives, and all persons
acting in concert with her and participating with her, directly or indirectly) from
violating the Waiver of Standing Clause in the Final Judgment and in the
Settlement Agreement by demanding information, seeking an accounting, or
asserting any claim or cause of action in connection with a trust for the primary
benefit of a descendant of Margaret Hunt Hill of which she is not a current
beneficiary, including but not limited to the [Lyda Hunt–Margaret Trust]; and
• 	order[ing] Caroline to dismiss with prejudice the lawsuit known as Cause No.
PR-25-02919-2, Caroline M. Hill v. Margaret Keliher (as Independent Executor
of the Estate of Albert G. Hill, Jr., Deceased), Carol E. Irwin (as Independent
Executor of the Estate of Ivan Irwin, Jr., Deceased), Joyce E. Waller (as Co-
Trustees of the Lyda Hunt-Margaret Trusts f/b/o Albert G. Hill, Jr.), and
Galatyn Finance, LLC, Probate Court No. 2, Dallas County, Texas.
Id. at 16-17. Movants also seek attorney’s fees and costs pursuant to the terms of the GSA. Id. at
17-18.
On January 6, 2026, Caroline Hill initially filed her response brief.10 She contends, among
other things, that (1) “this Court lacks subject matter jurisdiction, which it acknowledged in 2018,
because the Lyda Hunt[–Margaret Trust] was never a part of the settlement, the Final Judgment,
or the 1935 trusts derived from the instruments at issue in this case”; and (2) “the Anti-Injunction
Act categorically bears the relief Movants seek, as none of the narrow exceptions apply.” Doc.
2062 at 5. On January 13, 2026, Movants filed their reply. Accordingly, the Motion is ripe for
disposition.
10 On January 14, 2026, the court directed Caroline Hill to refile her Response and omit the GSA and Final
Judgment (Doc. 2061). She complied with the court’s directive on January 16, 2026 (Doc. 2062).
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II. Analysis
A. Jurisdiction
Before turning to the parties’ jurisdictional arguments, the court first addresses the scope
of its continuing jurisdiction. Federal courts are courts of limited jurisdiction and must have
statutory or constitutional power to adjudicate a claim. Kokkonen v. Guardian Life Ins. Co., 511
U.S. 375, 377 (1994) (citations omitted); Home Builders Ass’n of Miss., Inc. v. City of Madison,
143 F.3d 1006, 1010 (5th Cir. 1998).
On December 3, 2007, Defendants removed this action to federal court asserting federal
question jurisdiction under 28 U.S.C. § 1331 based on Hill III’s federal RICO claim. See Doc. 1
at 2-3. In the Final Judgment, the court expressly dismissed with prejudice “all claims, causes of
action, counterclaims, crossclaims, and any other relief asserted or that could have been asserted,”
including the RICO claim—the only claim supporting federal question jurisdiction. Doc. 999 at
39. While the court’s dismissal of all claims in this case eliminated its jurisdiction, in the Final
Judgment, the court incorporated the GSA and retained jurisdiction to hear and resolve certain
limited issues:
IT IS ORDERED that, without affecting the finality of this Final Judgment,
the Court hereby retains continuing jurisdiction over the implementation of the
[Settlement] Agreement, the Final Judgment, and the Parties for purposes of
implementing and enforcing the [Settlement] Agreement and this Final Judgment.
IT IS FURTHER ORDERED that any controversy or claim arising after the date of
execution of the [Settlement] Agreement and arising out of the [Settlement]
Agreement or the Documentation shall be resolved by this Court. Each of the
Agreeing Parties agrees and covenants not to, and IT IS ORDERED that none of
the Agreeing Parties shall, file or assert any of the released Claims (in law or in
equity).
Doc. 999 at 43, ¶ 45.
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As previously explained, only July 3, 2018, the court rejected Hill III’s attempt to expand
the reach of the court’s continuing jurisdiction under paragraph 45 of the Final Judgment beyond
the MHTE and HHTE when he challenged the dissolution of the Lyda Hunt–Margaret Trust and
sought an injunction to preserve the assets of the Lyda Hunt–Margaret Trust. Hill, 2018 WL
3239795, at *11. In its ruling, the court recognized that the: “Settlement Agreement and Final
Judgment only modified the MHTE and HHTE.” Id. at 7 (original emphasis). Additionally, the
court noted the limited nature of its continuing jurisdiction, when it stated:
With respect to any Hunt/Hill family trusts other than the MHTE and HHTE,
therefore, this court does not have continuing jurisdiction, and issues pertaining to
those family trusts are not properly before this court. The court declines to expand
its continuing jurisdiction beyond the implementation and enforcement of the
Settlement Agreement and Final Judgment.
Id. (original emphasis).
With this background in mind, the court now addresses the parties’ arguments regarding
whether its continuing jurisdiction extends to the relief Movants seek. The court determines that
its continuing jurisdiction does not apply to this subsequent, legal brouhaha between the parties.
Movants attempt to invoke the court’s continuing jurisdiction under the Final Judgment.
First, they assert that Caroline Hill, by filing the State Probate Case, “is violating the Waiver of
Standing Clause in the [GSA] and the Final Judgment which prevents her from seeking an
accounting or asserting claims about a trust of which she is not a current beneficiary.” Doc. 2056
at 5. Next, they contend that, among other provisions, the court “specifically incorporated the
Waiver of Standing Clause into its Final Judgment, which specifically states that this Court retains
continuing jurisdiction over the implementation of the [GSA], the Final Judgment, and the Parties
for purposes of implementing and enforcing the [GSA] and the Final Judgment.” Doc. 2056 at 7-
8. Movants also note that, “[s]ince entering the Final Judgment in November 2010, this Court has
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repeatedly acknowledged and exercised its exclusive jurisdiction relating to the Settlement
Agreement and the Final Judgment entering numerous orders enforcing the Final Judgment.” Id.
at 8. In the alternative, Movants argue that “the All Writs Act authorizes the Court to enjoin
Caroline [Hill] from violating the Final Judgment by pursuing the Lawsuit.” Id. at 9.
In response, Caroline Hill asserts as follows:
Movants’ Motion to Enforce is not a good-faith effort to implement a
federal judgment. It is an attempt to avoid answering basic fiduciary questions
properly raised in Texas probate court. Rather than defend their conduct in the
forum charged with supervising trusts, Movants seek to use this Court’s prior
settlement as a shield against scrutiny that settlement never contemplated.
Doc. 2062 at 9. Caroline Hill argues that the Motion should be denied “because this Court lacks
subject-matter jurisdiction.” Specifically, she asserts:
The Court’s limited retention of jurisdiction in the Final Judgment authorizes only
enforcement of the Settlement Agreement as written and does not extend to the
Lyda Hunt–Margaret Trust, a separate trust that was never litigated, mentioned, or
incorporated into the Settlement Agreement or Final Judgment. Movants’ attempt
to stretch the Waiver of Standing provision to reach the Lyda Trust contradicts the
plain language of the agreement, produces absurd results under Texas law, and
conflicts 	with 	this 	Court’s 	prior 	rulings 	expressly 	limiting 	its 	continuing
jurisdiction to the MHTE and HHTE—not the Lyda Trust.
Id. (emphasis added).
In reply, Movants reiterate their argument that the “Waiver of Standing Clause prohibits
[Caroline Hill] from demanding information, seeking an accounting, or asserting any claim in
connection with any trust for the primary benefit of a descendant of Margaret Hunt Hill [an MHH
Trust] based upon action and inaction when [she] was not a current beneficiary.” Doc. 2060 at 7.
They contend “there is a genuine controversy between the parties regarding the interpretation and
application of the Waiver of Standing Clause in the [GSA] and the Final Judgment, and this Court
has the exclusive jurisdiction to determine this dispute.” Id. at 3.
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Notably absent from Movants’ Motion and reply brief is any acknowledgment or
discussion of the court’s July 3, 2018 ruling that “[w]ith respect to any Hunt/Hill family trusts
other than the MHTE and HHTE, therefore, this court does not have continuing jurisdiction, and
issues pertaining to those family trusts are not properly before this court.” Hill, 2018 WL 3239795,
at *7. Instead, in their reply brief, Movants contend that the “Waiver of Standing Provision is not
limited to only the MHTE and HHTE.” Doc. 2060 at 4. Further, they assert that:
This Court’s prior orders did not (and could not) rewrite the Waiver of Standing
Clause to narrow its application to only the MHTE or the HHTE. And the Court
has never held that: (1) the parties to the Settlement Agreement and Final Judgment
only agreed to waive standing relating to the trusts at issue the MHTE and HHTE;
or (2) the “waiver” was limited to only those trusts.
Id. at 6 (internal punctuation omitted).
In making these statements, Movants misapprehend the essence of the court’s July 3, 2018
decision, namely, that its continuing jurisdiction in this matter did not extend to “Hunt/Hill family
trusts other than the MHTE and HHTE . . . .” Hill, 2018 WL 3239795, at *7. In light of the court’s
statement concerning the scope of its continuing jurisdiction, it did not need to rule, definitively,
on the application, vel non, of the Waiver of Standing Clause to separate trusts that were never
litigated, mentioned, or incorporated into the GSA or Final Judgment. Further, the court lacks
authority to “render an advisory opinion on hypothetical or abstract facts.” U.S. Bank Tr. Nat’l
Ass’n as Tr. of Tiki Series IV Tr. v. Walden, 124 F.4th 314, 323 (5th Cir. 2024) ( citation omitted).
This rule “ensure[s] that federal courts determine specific disputes between parties, rather than
hypothetical legal questions, and in doing so, conserve judicial resources.” Texas v. Travis Cnty.,
272 F. Supp. 3d 973, 980 (W.D. Tex. 2017) (citing Flast v. Cohen, 392 U.S. 83, 96-97 (1968)),
aff’d, 910 F.3d 809 (5th Cir. 2018).
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The court previously determined that it lacked jurisdiction over Hunt/Hill family trusts
other than the MHTE and HHTE. Hill, 2018 WL 3239795, at *7. Movants offer no explanation
for their failure to address the court’s scope of jurisdiction, as enunciated by the undersigned on
July 3, 2018, which unequivocally does not extend to issues arising under the Lyda Hunt–Margaret
Trust. As such, the court determines Movants have forfeited and waived any argument they might
seek to make in this regard. Although there is a difference between forfeiture and waiver, the court
believes both have been satisfied in this instance. As aptly described by the United States Supreme
Court, “[w]aiver is different than forfeiture. Whereas forfeiture is the failure to make the timely
assertion of a right, waiver is the intentional relinquishment or abandonment of a known right.”
United States v. Olano, 507 U.S. 725, 733 (1993) (internal quotation marks and citations omitted).
Here, Movants should have raised and addressed the court’s previous ruling—limiting its
continuing jurisdiction to issues arising out of the MHTE and HHTE—in their Motion and reply.
In any event, it was incumbent upon Movants to address the court’s jurisdictional ruling in their
reply brief, as it was a substantial part of Caroline Hill’s response to the Motion. Instead, Movants
limit their focus to the terms of the Waiver of Standing Clause, to the exclusion of all else.
Movants’ cursory discussion of the Waiver of Standing Clause in their reply brief does not put the
issue in play. In other words, an oblique discussion of matters unrelated to the court’s limited
retention of jurisdiction constitutes inadequate briefing. That Movants were on notice and did not
address the court’s jurisdictional limitations in a timely manner constitutes a forfeiture and a
waiver. Knowing the court’s continuing jurisdiction under the Final Judgment is of paramount
significance—as Hill III’s RICO claims have been dismissed with prejudice, leaving no federal
claims—Movants ignored it. The only reasonable inference the court is able to make is that
addressing the jurisdictional parameters of the court’s continuing jurisdiction, as enunciated by the
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Memorandum Opinion and Order – Page 18
court in its July 3, 2018 decision, would be adverse to Movants’ current position. Moreover,
Movants were clearly on notice of the court’s earlier decision in which it unambiguously ruled that
its exercise of continuing jurisdiction was limited to the MHTE and HHTE, yet they did not address
this earlier decision of the court in their initial brief. Movants’ failure to directly address the
parameters of the court’s continuing jurisdiction, as articulated in its July 3, 2018 decision,
constitutes forfeiture.
In addition, relevant authority from the Fifth Circuit establishes that Movants have also
waived their argument regarding jurisdiction. A litigant’s failure to raise, address, or brief an
argument in the district court constitutes a waiver of that issue on appeal. Fruge v. Amerisure Mut.
Ins. Co., 663 F.3d 743, 747 (5th Cir. 2011) (“Failure to raise an argument before the district court
waives that argument” on appeal); Lookingbill v. Cockrell, 293 F.3d 256, 264 (5th Cir. 2002)
(same) (citations omitted); see also Nichols v. Enterasys Networks, Inc., 495 F.3d 185, 190 (5th
Cir. 2007) (explaining that inadequately briefed issues are considered waived) (citing Burnley v.
City of San Antonio, 470 F.3d 189, 200 n.10 (5th Cir. 2006)) (“Burnley also seeks an award of
appellate attorney’s fees, but provides neither legal authority nor evidence in support of such an
award. Accordingly, her argument is waived for inadequate briefing.”); Mullins v. TestAmerica,
Inc., 564 F.3d 386, 407 n.9 (5th Cir. 2009) (a single sentence claim that a subrogation clause
required payment, without further explanation, justified waiver on grounds of inadequate briefing)
(citing Nichols, 495 F.3d at 190).
District courts have concluded, by analogy, that the failure to address, brief, or respond to
an argument or issue in the district court also waives that argument or issue in the district court.
See, e.g., Magee v. Life Ins. Co. of N. Am., 261 F. Supp. 2d 738, 748 n.10 (S.D. Tex. 2003)
(“[F]ailure to brief an argument in the district court waives that argument in that court”); see also
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Kellam v. Metrocare Servs., 2013 WL 12093753, at *3 (N.D. Tex. May 31, 2013) (Solis, J.)
(“Generally, the failure to respond to arguments constitutes abandonment or waiver of the issue.”)
(internal quotation marks omitted), aff’d, 560 F. App’x 360 (5th Cir. 2014); Grimes v. Santander
Consumer USA, 2023 WL 5022276, at *5 n.6 (N.D. Tex. July 13, 2023) (Ramirez, J.), report and
recommendation adopted by, 2023 WL 5021786 (N.D. Tex. Aug. 5, 2023) (Starr, J.) (“While the
‘issues-not-adequately briefed-are-waived rule’ in [Fifth Circuit] cases derives from the Federal
Appellate Rules of Procedure, Local Civil Rule 7.1 similarly requires motions and responses to be
‘accompanied by a brief that sets forth the moving party’s contentions of fact and/or law, and
argument and authorities.’”) (cleaned up) (citation omitted).
The Fifth Circuit has also held that a party abandons a theory of recovery or defense by
failing to pursue or defend it during the course of litigation in the district court. See Black v. North
Panola Sch. Dist., 461 F.3d 584, 588 n.1 (5th Cir. 2006) (“[Plaintiff’s] failure to pursue [her] claim
beyond her complaint constituted abandonment.”); Vela v. City of Houston, 276 F.3d 659, 679 (5th
Cir. 2001) (“The vague language [in defendant’s original pleading] coupled with the complete
absence of the issue in all subsequent documents” constituted abandonment of the defense.);
Hargrave v. Fibreboard Corp., 710 F.2d 1154, 1164 (5th Cir. 1983) (a party “in his [or her]
opposition to a motion for summary judgment cannot abandon an issue and then . . . by drawing
on the pleadings resurrect the abandoned issue.”) (citation and internal quotation marks omitted).
Finally, even if the court were to entertain Movants’ contention that the Waiver of Standing
Clause requires it to enjoin Caroline Hill from seeking an accounting related to the Lyda Hunt–
Margaret Trust, as she “is not a current beneficiary of a trust for the primary benefit of a descendant
of [Margaret Hunt Hill]”—an argument that fails to address head-on the court’s July 3, 2018
decision in which it declined to expand its continuing jurisdiction to reach the Lyda Hunt–Margaret
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Memorandum Opinion and Order – Page 20
Trust—applying Movants’ interpretation of the Waiver of Standing Clause would lead to an absurd
result. Under Texas law, which both parties agree applies here, a court is to avoid when possible
“a construction [that] is unreasonable, inequitable, and oppressive.” Reilly v. Rangers Mgmt., Inc.,
727 S.W.2d 527, 530 (Tex. 1987); see also Pavecon, Inc. v. R-Com, Inc., 159 S.W.3d 219, 222
(Tex. App.—Fort Worth 2005, no pet.) (stating that when interpreting a contract, a court should
avoid, if possible, “a construction that is unreasonable, inequitable, or oppressive, or would lead
to an absurd result.”) (emphasis added).11
The absurdity or unreasonableness of Movants’ position is straightforward: this matter,
concluded in 2010, would continue ad infinitum, as Movants would be given a blank check to
continue this litigation for successive generations. As the Fifth Circuit aptly and previously noted,
“[a]fter ‘protracted [and] complicated’ litigation, Hill v. Schilling, 593 F. App’x 330, 331 (5th Cir.
2014), squabbling over the trusts was supposedly ended by a settlement agreement confected in
2010. Yet, over the next four years, our court ‘weighed in on the settlement’ four times. Id. This
11 “In construing a contract under Texas law, courts must examine and consider the entire writing and give
effect to all provisions such that none are rendered meaningless.” International Turbine Servs., Inc. v. VASP
Brazilian Airlines, 278 F.3d 494, 497 (5th Cir. 2002) (citing Coker v. Coker, 650 S.W.2d 391, 393 (Tex.
1983)). Contract provisions “cannot be read in isolation; all of the provisions must be considered with
reference to the whole.” In re Ford Motor Co., 211 S.W.3d 295, 298 (Tex. 2006); J.M. Davidson, Inc. v.
Webster, 128 S.W.3d 223, 229 (Tex. 2003) (“No single provision taken alone will be given controlling
effect; rather, all the provisions must be considered with reference to the whole instrument.”). Contract
provisions must also be interpreted “so as to avoid meanings that produce unreasonable, oppressive, or
absurd results.” Mid-Continent Cas. Co. v. Bay Rock Operating Co., 614 F.3d 105, 114 (5th Cir. 2010)
(citation omitted); Frost Nat’l Bank v. L & F Distribs., Ltd., 165 S.W.3d 310, 311 (Tex. 2005) (per curiam)
(“[C]ourts construe contracts from a utilitarian standpoint bearing in mind the particular business activity
sought to be served, and will avoid when possible and proper a construction [that] is unreasonable,
inequitable, and oppressive.”). In addition, courts “presume parties intend what the words of their contract
say” and “strive to honor the parties’ agreement and not remake their contract by reading additional
provisions into it.” Gilbert Tex. Const., L.P. v. Underwriters at Lloyd’s London, 327 S.W.3d 118, 126 (Tex.
2010) (citations omitted).
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Memorandum Opinion and Order – Page 21
appeal makes it five.” Hill v. Washburne, 953 F.3d at 301. Unfortunately, the “squabbling” has not
relented since the Fifth Circuit made its pronouncement more than five years ago in 2020.
Caroline Hill provides two hypotheticals to demonstrate the problems with Movants’
attempt to use the Waiver of Standing Clause to enjoin the State Probate Case:
Under Movants’ interpretation, [the Waiver of Standing Clause] would apply if Ms.
Hill’s father created a trust from lottery winnings with Caroline as the primary
beneficiary 	and 	her 	two 	brothers 	as 	contingent 	beneficiaries. 	Accordingly,
Movants’ position must be rejected because it would create an absurd result.
Similarly, if Ms. Hill created a trust from lottery winnings for her children, section
5(b) would apply to that trust. Once again, this absurdity demonstrates the fallacy
in Movants’ position.
Doc. 2062 at 13 (footnote omitted).
The court is mindful that the Lyda Hunt–Margaret Trust is a separate trust that was never
litigated, mentioned, or incorporated into the GSA or Final Judgment. Movants’ attempt to expand
and stretch the Waiver of Standing provision to reach the Lyda Hunt–Margaret Trust not only
produces absurd and unreasonable results under Texas law, see supra, but also conflicts with this
court’s prior ruling expressly limiting its continuing jurisdiction to the MHTE and HHTE—not
the Lyda Hunt–Margaret Trust.
For these reasons, the court concludes that, while it retains continuing jurisdiction with
respect to any controversy or claim arising after the date of execution of the GSA and arising out
of the GSA pursuant to paragraph 45 of the Final Judgment, its continuing jurisdiction only reaches
as far as the MHTE and HHTE—the specific trusts at issue in this litigation—and it does not
extend to issues involving the Lyda Hunt–Margaret Trust.
This determination is consistent with the court’s prior ruling (see Hill, 2018 WL 3239795,
at *7, *11) rebuffing Hill III’s challenge to Hill Jr.’s and his co-trustees’ 2016 dissolution of the
Lyda Hunt–Margaret Trust, as well as Hill III’s attempt to invoke the court’s continuing
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Memorandum Opinion and Order – Page 22
jurisdiction by seeking an injunction to preserve the assets of the Lyda Hunt–Margaret Trust and
to prevent the dissipation, concealment, and further transfer of its assets. See Doc. 1877. Movants’
requested relief with respect to Caroline Hill’s actions is akin to Hill III’s requested relief with
respect to Hill Jr.’s and his co-trustees’ dissolution of the Lyda Hunt–Margaret Trust. Both seek
to invoke the court’s continuing jurisdiction to enjoin actors in state court raising issues arising
under Hunt/Hill family trusts other than the MHTE and HHTE. When the court rejected Hill III’s
attempts to enjoin Hill Jr. and his co-trustees from dissolving the Lyda Hunt–Margaret Trust,
concluding its lacked continuing jurisdiction with respect to Hunt/Hill family trusts other than the
MHTE and HHTE, there was nary an outcry from Movants (or any other party). In acting as an
umpire, the court calls balls, outs, and strikes as to both teams. The participants expect such calls
to be fair and even-handed, and the court is merely performing its judicial obligations consistent
with its prior ruling. Therefore, the court sees no pathway to expand its jurisdiction and hold that
the actions taken by Caroline Hill in the State Probate Case fall within the ambit of the MHTE and
HHTE and, concomitantly, the reach of the court’s continuing jurisdiction.12
In addition, the court declines to accept Movants’ invocation of the All Writs Acts as an
alternative theory of jurisdiction. See Doc. 2056 at 9-10. The All Writs Act does not provide an
independent grant of jurisdiction. See 28 U. S. C. § 1651(a) (permitting writs “necessary or
appropriate in aid of” a court’s jurisdiction). The “express terms of the All Writs Act confine a
12 Movants appear to think that the court’s continuing jurisdiction is unlimited. Such is not the case. Even
if the court were to accept Movants’ argument that Caroline Hill’s actions pertaining to the Lyda Hunt–
Margaret Trust fall within its continuing jurisdiction, this case could go on indefinitely. In other words, if
the court does not take a common-sense approach, this matter could continue ad infinitum. All parties
involved in the settlement contemplated that there would be an eventual cessation to this litigation, initiated
by Hill III in 2007, concerning “the management of two trusts created by the late Texas oil magnate H.L.
Hunt.” Hill v. Schilling, 495 F. App’x 480, 482 (5th Cir. 2012). Otherwise, they would not have agreed to
settle the litigation.
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Memorandum Opinion and Order – Page 23
court ‘to issuing process in aid of its existing statutory jurisdiction; the Act does not enlarge that
jurisdiction.’” Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28, 33 (2002) (cleaned up) (quoting
Clinton v. Goldsmith, 526 U.S. 529, 534-535 (1999)). This Act is to be construed narrowly and
applied “only under such extraordinary circumstances . . . that indisputably demand such a course
of action as absolutely necessary to vouchsafe the central integrity of the federal court judgment.”
Singh v. Duane Morris LLP, 538 F.3d 334, 341 (5th Cir. 2008) (original ellipses and emphasis)
(citation omitted). Movants have failed to persuade the court that invocation of the All Writs Act
here is either appropriate or warranted.
For these reasons, the court denies the Motion for lack of jurisdiction. As the court lacks
jurisdiction, it cannot address Movants’ application for a temporary restraining order, preliminary
injunction, or permanent injunction.
B. The Anti-Injunction Act
In addition, as a separate and independent reason to deny the Motion, the court agrees with
Caroline Hill that the Anti-Injunction Act precludes Movants from obtaining the requested relief.
The Anti-Injunction Act (the “Act”) provides that “A court of the United States may not
grant an injunction to stay proceedings in a State court except as expressly authorized by Act of
Congress, or where necessary in aid of its jurisdiction, or to protect or effectuate its judgments.”
28 U.S.C. § 2283. As the United States Supreme Court has noted, the Act “goes back almost to
the beginnings of our history as a Nation,” and its basic purpose is to avert “needless friction
between state and federal courts.” Mitchum v. Foster, 407 U.S. 225, 231-32 (1972).
Caroline Hill contends that “[t]he relief that Movants seek—enjoining a pending state court
proceeding—falls within the plain language of the Anti-Injunction Act[] and does not satisfy any
of the three narrow exceptions.” Doc. 2062 at 10-11. The court agrees, as the Act contains three
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Memorandum Opinion and Order – Page 24
limited and narrow exceptions. 28 U.S.C. § 2283. Those exceptions only apply when the injunction
is (1) expressly authorized by an Act of Congress; (2) necessary to aid a federal court in its
jurisdiction; or (3) necessary to protect or effectuate the federal court’s judgments. Id. Federal
courts cannot enjoin state court proceedings unless an injunction fits precisely within one of the
Anti-Injunction Act’s three designated exceptions. Atl. Coast Line R.R. Co. v. Brotherhood of
Locomotive Eng’rs, 398 U.S. 281, 286 (1970). Otherwise stated, “the Act is an absolute prohibition
against any injunction of any state-court proceedings, unless the injunction falls within one of the
three specifically defined exceptions in the Act.” Vendo Co. v. Lektro-Vend Corp., 433 U.S. 623,
630 (1977). Further, the “Act’s purpose is to forestall the inevitable friction between the state and
federal courts that ensues from the injunction of state judicial proceedings by a federal court.” Id.
(citation omitted).
The first exception to the Act requires that the requested relief be expressly authorized by
an Act of Congress. 28 U.S.C. § 2283. Movants have not and cannot point to a single federal law
to establish that their request for relief is expressly authorized. Thus, the first exception has not
been satisfied.
The second exception to the Act permits a federal court to stay proceedings in a state court
only when an injunction is necessary to protect the federal court’s jurisdiction. Id. Under this
exception, courts “are guided by the overarching principle that federal courts are to be cautious
about infringing on the legitimate exercise of state judicial power.” State of Tex. v. United States,
837 F.2d 184, 186 (5th Cir. 1988) (citing Younger v. Harris, 401 U.S. 37, 44-45 (1971)). Movants
have not demonstrated that their requested relief is necessary to aid the court in the exercise of its
jurisdiction, specifically when the court has already explicitly narrowed its continuing jurisdiction
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Memorandum Opinion and Order – Page 25
in this case to disputes involving the MHTA and HHTE, trusts in the GSA and incorporated into
the Final Judgment.
The third exception to the Act allows a federal court to issue an injunction when necessary
to protect or effectuate its judgments. 28 U.S.C. § 2283. The Fifth Circuit applies a four-part test
to determine whether an injunction staying a state proceeding properly falls within this exception.
See New York Life Ins. Co. v. Gillispie, 203 F.3d 384, 387 (5th Cir. 2000). First, “the parties in a
later action must be identical to (or at least in privity with) the parties in a prior action.” Id. Second,
the judgment in the prior action must have been rendered by a court of competent jurisdiction. Id.
Third, “the prior action must have concluded with a final judgment on the merits.” Id. Fourth, the
“same claim or cause of action must be involved in both suits.” Id.
Although the first part of the test may be satisfied—as Caroline Hill is the Plaintiff in the
State Probate Case and was represented virtually in this case by her parents with respect to the
GSA and by a court-appointed guardian-ad-litem with respect to the Final Judgment—the
remaining three parts of the test have not been met. The second part of the test requires that the
Dallas Probate Court must have rendered a judgment—which has not occurred. The third part of
the test requires that the state court judgment must have been rendered on the merits—which has
not occurred. Finally, the fourth part of the test requires that the same claim or cause of action
must be involved in both suits—which is not the case. Under these circumstances, in the alternative
to denying the Motion for lack of jurisdiction, the court also denies the Motion under the Anti-
Injunction Act.13
13 In light of the court’s decision, it need not reach Caroline Hill’s remaining arguments that (1) “principles
of federal abstention independently preclude the extraordinary relief Movants seek[;]” and (2) “[e]ven if
the Court were to conclude that the [GSA] and Final Judgment somehow reached the Lyda Trust, which
they do not, federal jurisdiction is still foreclosed by the probate exception.” Doc. 2062 at 18, 20.
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III. 	Conclusion
For the reasons previously set forth herein, the court denies the Motion to Enforce Final
Judgment 	and 	Settlement 	Agreement 	and 	Application 	for 	Temporary 	Restraining 	Order,
Preliminary Injunction and Permanent Injunction (Doc. 2055). Further, all allowable and
reasonable costs of court incurred by Caroline Hill are taxed against Movants.
It is so ordered this 30th day of January, 2026.
_________________________________
Sam A. Lindsay
United States District Judge
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