in Re: John Henry Green, Jr., Individually and as Trustee of the Testamentary Trust Formed for the Benefit of William Casey Ellison and Gayla Jan Tibbits As Former Controlling Stockholder of National Foundry & Manufacturing Company, 527 S.W.3d 277

John H. Green Jr. is trustee of testamentary trusts created by his father’s will and is sued individually and as trustee for alleged breaches, fraud, misappropriation, and usurpation of corporate opportunities.
The plaintiffs (Ellison, Tibbits, and Edelmira Green) sued in Crane County district court; Green moved to transfer venue to Ector County under the mandatory venue statute for trust actions, Tex. Prop. Code §115.002(b)(2).
Green submitted an affidavit and documentary evidence showing he administered the trusts from his business office in Odessa (418 N. Texas Ave., Ector County) and received trust correspondence there.
Plaintiffs argued venue was proper in Crane County because the will was probated there and National Foundry (where Green was president) is located in Crane County; they submitted affidavits and corporate records tying Green and the corporation to Crane County.
The trial court denied Green’s motion to transfer and awarded plaintiffs $2,500 in attorney’s fees (apparently as sanctions under Tex. Civ. Prac. & Rem. Code §10.002).
The court of appeals granted mandamus: it found the situs-of-administration test controls (location of trustee’s office primarily responsible for dealing with settlor/beneficiaries), held the evidence supported transfer to Ector County, and found the fee award an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether venue under Tex. Prop. Code §115.002(b)(2) is proper in Crane County or Ector County	Situs of administration is in Crane County because the will was probated there and National Foundry (where Green operated) is in Crane County	Situs of administration is in Ector County because Green administered the trusts from his Odessa office and received trust correspondence and managed trust accounts there	Court held situs is the location of the trustee’s office primarily responsible for dealing with beneficiaries; evidence showed Green administered the trusts from Odessa; transfer to Ector County is required (mandamus granted)
Whether the trial court properly awarded $2,500 in attorney’s fees to plaintiffs as sanctions under Tex. Civ. Prac. & Rem. Code §10.002	Plaintiffs sought fees as sanctions, asserting Green’s transfer motion violated Rule 13 / §10.001 certifications	Green argued his motion was nonfrivolous and supported by evidentiary facts; no improper purpose shown	Court held the motion was not frivolous and there was no evidence of improper purpose; fee award as sanction was an abuse of discretion

In re Frank Kent Motor Co., 361 S.W.3d 628 (Tex. 2012) (mandamus standard for extraordinary relief)
In re Prudential Ins. Co. of Am., 148 S.W.3d 124 (Tex. 2004) (mandamus requirements and standards)
Walker v. Packer, 827 S.W.2d 833 (Tex. 1992) (trial court has no discretion in determining what the law is or applying law to facts)
In re Transcontinental Realty Investors, Inc., 271 S.W.3d 270 (Tex. 2008) (mandatory-venue statutes enforceable by mandamus)
In re Wheeler, 441 S.W.3d 430 (Tex. App.—Waco 2014) (treating §115.002 as mandatory venue provision)
In re Olshan Foundation Repair Co., LLC, 328 S.W.3d 883 (Tex. 2010) (abuse of discretion occurs when court fails to correctly analyze or apply law)
In re Mid-Century Ins. Co. of Tex., 426 S.W.3d 169 (Tex. App.—Houston [1st Dist.] 2012) (definition of abuse of discretion)