El Tacaso, Inc. v. Jireh Star, Inc., 356 S.W.3d 740

El Tacaso owns real property on Harry Hines Blvd, Dallas, where Gordita’s operated as a restaurant.
Jireh Star entered into a Lease and a 12-month License with El Tacaso in April 2007; Kim personally guaranteed performance.
Jireh Star elected to extend the License term by paying a one-time $158,000 license fee, evidenced by a Promissory Note with a cross-default provision.
El Tacaso sued Jireh Star and Kim for breach of the Promissory Note and related lease violations; Jireh Star counterclaimed for fraud, DTPA violations, negligent misrepresentation, breach of contract, tortious interference, breach of quiet enjoyment, and false imprisonment.
Jireh Star sought a temporary restraining order and a temporary injunction; the trial court granted a temporary injunction in Jireh Star’s favor.
El Tacaso appeals arguing the injunction was void for failure to comply with Rule 683, lack of irreparable harm, misalignment with the status quo, lack of jurisdiction, vagueness/overbreadth, and other defects; the appellate court agrees the order is void for Rule 683 noncompliance and reverses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the injunction complies with Rule 683 and is valid	El Tacaso argues the order is noncompliant and void	Jireh Star contends the order identifies harms and necessity	Void; Rule 683 mandatory; order dissolved and remanded
Whether the injunction adequately states irreparable harm	Irreparable harm was shown by likely loss of business and customers	The order lacks specific factual basis linking harm to irreparable injury	Void for failure to articulate irreparable harm with concrete reasons
Whether the injunction properly describes the acts restrained and the nexus to irreparable harm	Restrictive acts described; laches not raised	Described acts do not show linkage to irreparable harm	Void for lack of specific nexus to irreparable harm and actionable injury
Whether the court properly delineated why infringement would cause irreparable harm	Injunction necessary to prevent disruption of leasehold and business	No explicit factual basis provided for irreparable harm	Void; failure to meet Rule 683’s specificity requirement
Whether other Rule 683 defects undermine the injunction's validity	Rule 683 requirements satisfied in substance	Multiple mandatory elements missing or inadequately described	Void; remains reversible without addressing other issues

Butnaru v. Ford Motor Co., 84 S.W.3d 198 (Tex. 2002) (requirements for temporary injunctions; necessity of adequate prima facie showing of irreparable harm)
Qwest Commc’ns Corp. v. AT & T Corp., 24 S.W.3d 334 (Tex. 2000) (Rule 683 mandatory; injunctions must state reasons on face of order)
InterFirst Bank San Felipe v. Paz Const. Co., 715 S.W.2d 640 (Tex. 1986) (void injunctions that fail to define injury they prevent)
Cook United, Inc., 464 S.W.2d 105 (Tex. 1971) (mandatory nature of Rule 683; reasons must be stated)
San Antonio Bar Ass’n v. Guardian Abstract & Title Co., 291 S.W.2d 697 (Tex. 1956) (specificity requirement for temporary injunctions)
City of Corpus Christi v. Friends of the Coliseum, 311 S.W.3d 706 (Tex. App.-Corpus Christi 2010) (illustrates irreparable injury analysis in injunctions)