irreparable injury requirement in Texas

2019See Butler, 51 S.W.3d at 795 ; Sonwalkar, 394 S.W.3d at 197–99; see also TEX.

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex.1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief’ and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, 373 S.W.3d 748, 763-65 (Tex.App.-Houston [1

2025Second, an injury is irreparable if “damages cannot be measured by any certain pecuniary standard.” Butnaru, 84 S.W.3d at 204 .

2016As discussed above, some evidence adduced by iPic pertained to harm to iPic Houston’s goodwill and reputation. ‘While [goodwill and reputa-tional injuries] are not categorically irreparable, the irreparable injury requirement is satisfied when injuries of this nature are difficult to calculate or monetize.” Intercontinental Terminals, 354 S.W.3d at 895 ; see also Butnaru, 84 S.W.3d at 204 .

2025Further, “An injury is irreparable if the injured party cannot be adequately compensated in damages, or if the damages cannot be measured by any certain pecuniary standard.” Butnaru, 84 S.W.3d at 204 ; City of Dallas v. Brown, 373 S.W.3d 204, 208 (Tex. App.—Dallas 2012, pet. denied). 47.

2025Further, “An injury is irreparable if the injured party cannot be adequately compensated in damages, or if the damages cannot be measured by any certain pecuniary standard.” Butnaru, 84 S.W.3d at 204 ; City of Dallas v. Brown, 373 S.W.3d 204, 208 (Tex. App.—Dallas 2012, pet. denied). 47.

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex.1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief’ and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, 373 S.W.3d 748, 763-65 (Tex.App.-Houston [1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex. 1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief” and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, No. 14-10-00971-CV, 2012 WL 1951071, at *1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex.1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief’ and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, 373 S.W.3d 748, 763-65 (Tex.App.-Houston [1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex. 1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief” and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, No. 14-10-00971-CV, 2012 WL 1951071, at *1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex.1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief’ and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, 373 S.W.3d 748, 763-65 (Tex.App.-Houston [1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex. 1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief” and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, No. 14-10-00971-CV, 2012 WL 1951071, at *1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex.1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief’ and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, 373 S.W.3d 748, 763-65 (Tex.App.-Houston [1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex. 1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief” and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, No. 14-10-00971-CV, 2012 WL 1951071, at *1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex.1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief’ and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, 373 S.W.3d 748, 763-65 (Tex.App.-Houston [1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex. 1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief” and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, No. 14-10-00971-CV, 2012 WL 1951071, at *1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex.1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief’ and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, 373 S.W.3d 748, 763-65 (Tex.App.-Houston [1

2012See, e.g., State v. Tex. Pet Foods, 591 S.W.2d 800, 805 (Tex. 1979) (holding that “doctrine of balancing the equities has no application to this statutorily authorized injunctive relief” and affirming injunctions authorized by Texas Clean Air Act, Texas Water Quality Act, and Texas Renderers’ Licensing Act); Butler, 51 S.W.3d at 795 (holding that Covenants Not to Compete Act, which provides that court may award injunctive relief if promisor breaches non-compete covenant, does not require promisee to show irreparable injury); City of Houston v. Proler, No. 14-10-00971-CV, 2012 WL 1951071, at *1

2011See, e.g. , Frequent Flyer Depot , 281 S.W.3d at 228 (“Disruption to a business can be irreparable harm.

2011See, e.g., Frequent Flyer Depot, 281 S.W.3d at 228 (“Disruption to a business can be irreparable harm.

2016As discussed above, some evidence adduced by iPic pertained to harm to iPic Houston’s goodwill and reputation. ‘While [goodwill and reputa-tional injuries] are not categorically irreparable, the irreparable injury requirement is satisfied when injuries of this nature are difficult to calculate or monetize.” Intercontinental Terminals, 354 S.W.3d at 895 ; see also Butnaru, 84 S.W.3d at 204 .

2015Intercontinental Terminals Co., LLC v. Vopak N. Am., Inc., 354 S.W.3d 887, 895-896 (Tex. App.—Houston 1st 30 Dist. 2011)(trial court did not abuse its discretion in granting temporary injunction order).2 Dunn and the Gallery face irreparable harm, including the loss of business, good will, employees, and reputation for which there is no adequate remedy at law.

2025Further, when “the State files suit to enjoin ultra vires action by a local official, a showing of likely success on the merits is sufficient to satisfy the irreparable-injury requirement for a temporary injunction,” Hollins, 620 S.W.3d at 24 410, as “the ‘inability [of a State] to enforce its duly enacted [laws] clearly inflicts irreparable harm on the State,’” Tex. Ass’n of Bus. v. City of Austin, 565 S.W.3d 425, 441 (Tex. App.—Austin 2018, pet. denied) (quoting Abbott v. Perez, 138 S. Ct. 2305 , 2324 n.17 (2018)).

2024Hide & Rendering Co., 226 S.W.2d 615, 619 (Tex. 1950) (quoting Hill v. Brown, 237 S.W. 252, 255 (Tex. Comm’n App. 1922, judgm’t adopted)). 51 Defendants have not challenged on appeal the trial court’s conclusion that the irreparable injury requirement is satisfied.

2024Hide & Rendering Co., 226 S.W.2d 615, 619 (Tex. 1950) (quoting Hill v. Brown, 237 S.W. 252, 255 (Tex. Comm’n App. 1922, judgm’t adopted)). 51 Defendants have not challenged on appeal the trial court’s conclusion that the irreparable injury requirement is satisfied.

1989Thus, the irreparable injury requirement was satisfied in the case of Gluck v. Texas Animal Health Comm’n, 501 S.W.2d 412, 415 (Tex.Civ.App.—San Antonio 1973, writ ref’d n.r.e.).

1989Thus, the irreparable injury requirement was satisfied in the case of Gluck v. Texas Animal Health Comm'n, 501 S.W.2d 412, 415 (Tex.Civ.App.—San Antonio 1973, writ ref'd n.r.e.).