Steve Huynh, Individually Yvonne Huynh, Individually Huynh Poultry Farm, LLC D/B/A Steve Thi Huynh Poultry Farm D/B/A Huynh Poultry Farm T & N Poultry Farm, LLC Thinh Bao Nguyen, Individually Timmy Huynh Poultry Farm Timmy Huynh, Individually And Sanderson Farms, Inc. v. Frank Blanchard, Angelia Snow, Tanya Berry, Kimberly Riley, John Miller, Amy Miller, Chad Martinez, Emily Martinez, Mersini Blanchard, Malakoff Properties, LLC, and Ronny Snow, 694 S.W.3d 648

Neighbors sued multiple poultry farms (and their operators) for creating a private nuisance due to noxious, recurring odors affecting nearby property owners.
A jury found the poultry farms negligently and intentionally caused a nuisance, but characterized the nuisance as temporary—occurring intermittently, not regularly.
The trial court issued an injunction that effectively shut down the entire poultry operation as its first remedy.
The poultry farms (petitioners) appealed, arguing the evidence or findings did not support the injunction’s breadth, and that regulatory remedies under Texas law existed.
The Texas Supreme Court reviewed whether the total shutdown was proper, especially in light of statutory and regulatory odor abatement schemes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can a permanent injunction issue for a temporary nuisance?	Injunction is proper for ongoing harm, regardless of labeling.	Only damages are proper for temporary nuisances.	A permanent injunction can issue if future harm is likely.
Does the finding of a temporary nuisance preclude a finding of imminent harm?	No—harm will recur, so imminent harm exists.	"Temporary" means no imminent future harm.	Trial court can find imminent harm regardless of label.
Do damages offer an adequate legal remedy?	Damages do not prevent future nuisance; legal remedy is inadequate.	Damages suffice; further legal action can be taken if nuisance recurs.	Recurrence risks multiplicity of suits; damages inadequate.
Was the scope of the shutdown injunction proper?	Shutdown order was necessary to abate the nuisance.	Order goes beyond what evidence supports and lawful remedies.	Shutdown injunction too broad; must be tailored to regulatory standards.

Crosstex N. Tex. Pipeline, L.P. v. Gardiner, 505 S.W.3d 580 (Tex. 2016) (Nuisance law principles; jury is sole judge of facts and credibility)
Golden Eagle Archery, Inc. v. Jackson, 116 S.W.3d 757 (Tex. 2003) (Jury’s factual findings are binding on court; court applies equitable principles for relief)
Pike v. Tex. EMC Mgmt., LLC, 610 S.W.3d 763 (Tex. 2020) (Permanent injunction requirements: wrongful act, imminent harm, irreparable injury, lack of adequate legal remedy)
Schneider Nat’l Carriers, Inc. v. Bates, 147 S.W.3d 264 (Tex. 2004) (Characterization of nuisance as temporary or permanent does not control injunctive relief)
Holubec v. Brandenberger, 111 S.W.3d 32 (Tex. 2003) (Injunctions must be narrowly drawn and precise, not overly broad)