in Re Jp Morgan Chase Bank, N. A., in Its Corporate Capacity, and as Trustee of the Red Crest Trust U/T/A Dated May 9, 1985, and Phillip Mettham, 361 S.W.3d 703

Relators petitioned for writ of mandamus to compel venue transfer after trial court denied transfer.
Orca sued relators in DeWitt County for real property and mineral interests; claims include quiet title, fraud, and specific performance among others.
Relators argued Section 115.002 of the Texas Property Code requires venue in the county of administration of the trust (Tarrant County).
Orca argued venue is mandatory under Section 15.011 (real property venue) because the action concerns real property and quiet title.
Tribunal analyzed whether Section 115.001/115.002 apply to tort-like claims against a trustee and concluded they do not.
Court held that the 2007 amendments to Section 15.011 do not broaden Section 115.001 to encompass tort claims against a trustee.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 115.001/115.002 mandatory venue apply to Orca's tort claims?	Orca: venue governed by real-property statute; DeWitt as proper county.	Relators: 115.002 requires transfer to the trust's situs (Tarrant).	No; tort claims are not within 115.001(a)'s scope.
Do the 2007 amendments to §15.011 overrule prior law and require DeWitt venue?	Amendment broadens scope of §15.011 to include more proceedings.	Amendment overrules only exclusive-list cases and not tort claims against a trustee.	Amendment does not convert tort claims into §15.011 proceedings; no mandatory DeWitt transfer.

In re Transcon. Realty Investors, 271 S.W.3d 270 (Tex. 2008) (mandamus venue where statutory scheme controls; trusteeship context)
In re Tex. Dep’t of Transp., 218 S.W.3d 74 (Tex. 2007) (orig. proceeding on mandamus; venue rules considerations)
In re Guardianship of Gibbs, 253 S.W.3d 866 (Tex. App. Fort Worth 2008) (trust-related proceedings not necessarily ‘concerning trusts’)
Mobil Oil Corp. v. Shores, 128 S.W.3d 718 (Tex. App. Fort Worth 2004) (mere involvement of a trustee does not make suit ‘concerning trusts’)
In re Stark, 126 S.W.3d 635 (Tex. App. Beaumont 2004) (claims like fraud/breach not ‘concerning trusts’ under §115.001)
Carroll v. Carroll, 304 S.W.3d 366 (Tex. 2010) (discusses scope of Section 15.011 amendments)