in Re Mae Dean Wheeler Individually and as Successor Trustee of the Wheeler Family Trust, 441 S.W.3d 430

Mae Dean Wheeler (relator) is sued by Circle X Camp Cooley, Ltd. over enforcement of a Purchase and Sale Agreement concerning property/mineral interests in Robertson County.
Circle X’s petition sued Wheeler individually and as successor trustee of the Wheeler Family Trust, alleging breach and seeking specific performance.
Wheeler moved to transfer venue to Harris County under Tex. Prop. Code §115.002, asserting she is a non‑corporate trustee and the trust was administered in Harris County within the four years before suit.
Circle X opposed, arguing mandatory venue lies in Robertson County under Tex. Civ. Prac. & Rem. Code §15.011 because the suit concerns property located there and is a contract action, not a trust proceeding.
Trial court denied the transfer; Wheeler sought mandamus relief from the Tenth Court of Appeals, which stayed the trial court proceedings and reviewed whether §115.002 controls venue.

Issue	Plaintiff's Argument (Circle X)	Defendant's Argument (Wheeler)	Held
Whether §115.002 (Property Code) or §15.011 (C.P.R.C.) controls mandatory venue	§15.011 controls because the dispute is a contract/specific‑performance claim about property in Robertson County, not a trust action	§115.002 controls because the suit is against a trustee and the trust was administered in Harris County within the prior four years	§115.002 (Property Code) prevails under §15.016 C.P.R.C.; Property Code’s mandatory venue governs
Whether §115.001 applies to an action against a trustee that does not directly "concern" the trust instrument	§115.001 does not apply because the suit does not concern construction/admin of the trust	§115.001 applies to "all proceedings by or against a trustee" (as amended), so venue rules apply	§115.001 covers proceedings against a trustee; §115.002 mandatory venue applies
Whether mandamus is an appropriate remedy to enforce mandatory venue	Venue can be challenged on appeal	Relator sought mandamus to enforce mandatory venue immediately	Mandamus is appropriate to enforce a mandatory‑venue statute; relator need not show appeal is inadequate

In re Prudential Ins. Co., 148 S.W.3d 124 (Tex. 2004) (mandamus standard and adequacy of appellate remedy)
Walker v. Packer, 827 S.W.2d 833 (Tex. 1992) (mandamus review principles)
In re J.P. Morgan Chase Bank, N.A., 373 S.W.3d 610 (Tex. App.—San Antonio 2012) (application of §115.002 and interplay with chapter 15 venue provisions)
In re Transcon. Realty Investors, 271 S.W.3d 270 (Tex. 2008) (mandamus to enforce mandatory‑venue statute)
In re Tex. Dep’t of Transp., 218 S.W.3d 74 (Tex. 2007) (statutory mandatory venue provisions prevail over conflicting chapter 15 provisions)