No bond, no TI

In Expo Group v. Purdy, the Fifth Court addressed whether the temporary injunction and related bond satisfied Rule 684, which requires that the trial court “fix the amount of security to be given by the applicant,” i.e., set a bond. Because the temporary injunction order did not set a specific bond amount, the order was void from inception.

The Court further clarified that the cash already deposited into the court’s registry for a different purpose could not be used to satisfy the bond requirement under Rule 684. It referenced the supreme court’s opinion in Ex parte Lesher, which held that the intent of Rule 684 is to require a bond payable to the party against whom the injunction is issued before the order may lawfully issue. No. 05-24-00653-CV, Jan. 27, 2025 (mem. op.)