Case Explained: Storey Mountain, L.L.C. Plaintiff— v. JPMorgan Chase Bank, N.A Garnishee Daniel J. Weldon, Successor Trustee of the Mary Katherine Weldon Trust

Court: United States Court of Appeals for the Fifth Circuit Filed: 2026-06-04 The fifth-circuit affirmed the district court’s order vacating a prior garnishment ruling and dissolving Storey Mountain’s writ of garnishment against assets held in a spendthrift trust. The court determined that the district court correctly applied Texas law, specifically Tex. Prop. Code § 112.034, regarding the doctrine of merger. Under this standard, a spendthrift trust loses its protection only if the legal and beneficial interests merge, which occurs when the trustee is the sole beneficiary. The appellate court found no reversible error in the district court’s conclusion that the trust did not merge because the trust instrument named Katherine’s children as contingent secondary beneficiaries, meaning she was not the sole beneficiary. Although Storey Mountain initially failed to properly plead complete diversity of citizenship among its members and the defendant, necessitating a remand for jurisdictional discovery, the subsequent confirmation of diversity jurisdiction allowed the court to proceed to the merits. The practical consequence is that the trust assets remain protected from garnishment by Storey Mountain. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.