This question has been addressed in 1 Texas court opinion:
COA05 — February 6, 2026
In Estate of Lake Zack Hughes, a contestant challenged his alleged father's will, asserting he was an omitted biological son and claiming the will was a forgery. The trial court dismissed the contest and admitted the will to probate after the contestant failed to post a court-ordered security for costs and submitted a handwriting expert report that was not properly verified. On appeal, the Dallas Court of Appeals affirmed the judgment, holding that the trial court properly exercised its discretion in enforcing the Texas Estates Code's security requirements and the Rules of Evidence regarding unverified expert reports. The case underscores that a party's failure to bridge the gap between allegations and admissible evidence can lead to a final judgment without a trial.
Litigation Takeaway
“Procedural and evidentiary compliance is non-negotiable in inheritance and paternity litigation; failure to post court-ordered security or to verify expert reports with specific "penalty of perjury" language can result in the immediate dismissal of your claims.”