Hoist Liftruck Mfg, Inc. v. Carruth-Doggett, Inc., 485 S.W.3d 120

Toyota Lift is a Houston-area material-handling equipment dealer.
Hoist Liftruck Mfg., Inc. and Toyota Lift entered into a dealer agreement in 2006 authorizing sales and service within a defined territory.
A dispute over compliance with the dealer agreement led Hoist to claim breaches and threaten termination if cured in 60 days.
Toyota Lift sought actual damages and injunctive relief in response.
A trial court granted Toyota Lift’s temporary injunction but the order did not state the reasons for issuance, prompting Hoist to appeal in this accelerated interlocutory proceeding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the temporary-injunction order complies with Rule 683.	Hoist argues the order fails to set forth the reasons for issuance.	Toyota Lift contends the order is proper despite any stated reasons.	The injunction is void for failure to state reasons and is dissolved.

Butnaru v. Ford Motor Co., 84 S.W.3d 198 (Tex. 2002) (standard for temporary injunctions; preservation not addressed here)
Helix Energy Sol. Grp., Inc. v. Howard, 452 S.W.3d 40 (Tex.App.-Houston [14th Dist.] 2014) (Rule 683 requires explicit reasons for issuance; defect makes order void/dissolvable)
InterFirst Bank San Felipe, N.A. v. Paz Constr. Co., 715 S.W.2d 640 (Tex. 1986) (Rule 683 defects are procedural; orders not compliant may be void/dissolved)
Qwest Comm. Corp. v. AT&T Corp., 24 S.W.3d 334 (Tex. 2000) (Rule 683 defects are procedural; not jurisdictional; voidability discussed)
El Tacaso, Inc. v. Jireh Star, Inc., 356 S.W.3d 740 (Tex.App.-Dallas 2011) (mandatory Rule 683 requirements; irreparable injury focus)