James E. White, IV, Individually and as Beneficiary of the Jane White Trust; Marti White Wright, Individually and as a Beneficiary of the Jane White Trust; And Clinton Wesley White, Individually and as a Beneficiary of the Jane White Trust, by and Through His Next Friend, James E. White, IV and James White, III, Individually and as Trustee of the Jane White Trust v. Edward McMinn White, Individually and as Trustee of the Edward McMinn White Trust, and Beauregard Brite White, Individually and as Trustee of the Beauregard Brite White Trust and Susan Combs, Temporary Interim Trustee of the White Division Trusts, 08-23-00243-CV

The case is a dispute among siblings regarding the administration and income distribution of the Jane White Trust, whose primary asset is the historic Brite Ranch in West Texas.
Jim White, III (Jim) served as trustee from 2010, with his two brothers, Mac and Beau, and his sister, Hester Ann, as income beneficiaries. In 2018, Mac and Beau sued Jim for breaches of fiduciary duty and self-dealing.
Mac and Beau alleged Jim failed to act as a prudent investor by continuing unprofitable ranching operations and failing to distribute income, and that Jim engaged in self-dealing by compensating himself and family excessively without full disclosure.
The jury found Jim breached his fiduciary duties; the trial court entered judgment removing Jim as trustee, awarding $1 million in damages to the trust and $1.5 million in exemplary damages each to Mac and Beau, and divided the trust into four new "Division Trusts".
Jim and intervening contingent remainder beneficiaries (Jim's children) appealed, arguing, among other things, fundamental errors in the jury charge.
The appeal turns on whether the jury instructions improperly shifted the burden of proof to Jim on all fiduciary duty claims, not just on claims of self-dealing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jury Charge: Burden of Proof	Jim had broad fiduciary duties and should bear the burden to prove compliance with all	Only in cases of self-dealing does trustee bear burden; general breaches require plaintiffs to prove	Question improperly shifted burden; new trial granted
Breach of Fiduciary Duty	Jim failed prudent investment, withheld distributions, self-dealt excessive compensation	Actions were in good faith, compensation reasonable, business judgment/exculpatory clauses apply	General fiduciary breach finding vacated due to jury charge error
Damages and Trust Modification	Sought damages for lost trust value/profit, exemplary damages, trust restructured to allow partition	Damages unsupported; trust modification unneeded; damages and equitable relief improper	Damages and modifications vacated; remand for new trial
Intervenor Status (Standing/Notice)	Intervenors necessary as contingent remainder beneficiaries, denied notice	Late intervention; not necessary/notice not required	Intervenors' appeal moot due to remand

First United Pentecostal Church of Beaumont v. Parker, 514 S.W.3d 214 (Tex. 2017) (sets default burden of proof on breach of fiduciary duty claims)
Stephens County Museum, Inc. v. Swenson, 517 S.W.2d 257 (Tex. 1974) (self-dealing transactions presumptively unfair; burden shifts to fiduciary)
Int’l Bankers Life Ins. Co. v. Holloway, 368 S.W.2d 567 (Tex. 1963) (fiduciary must prove fairness, good faith, disclosure in self-dealing)
Crown Life Ins. Co. v. Casteel, 22 S.W.3d 378 (Tex. 2000) (harm from broad-form submission of jury questions across multiple legal theories)