Can Texas courts issue protective orders when there are problems with paperwork or other pending cases?

Q: Can Texas courts issue protective orders when there are problems with paperwork or other pending cases?

Tatum v. Noble: Failing to show up for a scheduled hearing is a major risk; a judge recusing themselves or a case being moved to a different courtroom in the same building does not require the other party to re-serve you with notice before a default order is signed. | Anum Kamran Sattar v. Ryan Zedrick Hazlitt: To secure a protective order, an applicant must provide credible evidence of physical harm or imminent threats; general "bad behavior," infidelity, or emotional manipulation does not meet the statutory definition of family violence in Texas.

This question has been addressed in 2 Texas court opinions:

Tatum v. Noble

COA14 — February 24, 2026

In Tatum v. Noble, a respondent failed to appear for a protective order hearing in the 280th District Court. Following the presiding judge's sua sponte recusal, the case was immediately transferred to the 245th District Court within the same county, where the judge issued a default protective order. The respondent challenged the order, claiming the court lacked jurisdiction due to missing administrative forms and that her due process rights were violated because she was not served with new notice for the second courtroom. The Fourteenth Court of Appeals affirmed the order, holding that administrative "Registry" forms are not jurisdictional requirements. Furthermore, under Texas 'exchange of benches' statutes, a respondent who has already defaulted by failing to appear at the originally noticed time and place is not entitled to new formal notice when the matter is moved to another district court in the same county.

Litigation Takeaway

“Failing to show up for a scheduled hearing is a major risk; a judge recusing themselves or a case being moved to a different courtroom in the same building does not require the other party to re-serve you with notice before a default order is signed.”

Anum Kamran Sattar v. Ryan Zedrick Hazlitt

COA05 — February 11, 2026

In Sattar v. Hazlitt, the Dallas Court of Appeals reviewed a trial court's denial of Anum Sattar's application for a protective order against Ryan Hazlitt. The case arose from "dueling" protective order filings, with Sattar claiming a history of emotional abuse and a specific instance involving a firearm. The trial court excluded testimony regarding Hazlitt's emotional slights and manipulative behavior, focusing strictly on whether the conduct met the definition of "family violence" under Texas Family Code § 71.004. The appellate court affirmed the denial, holding that the trial court did not abuse its discretion in finding Sattar's testimony about physical threats lacked credibility and that general interpersonal misconduct is insufficient to warrant a Title 4 protective order.

Litigation Takeaway

“To secure a protective order, an applicant must provide credible evidence of physical harm or imminent threats; general "bad behavior," infidelity, or emotional manipulation does not meet the statutory definition of family violence in Texas.”