Chimp Haven, Inc. v. Primarily Primates, Inc

In Chimp Haven, Inc. v. Primarily Primates, Inc., 281 S.W.3d 629, 633 (Tex. App.--San Antonio 2009, no pet.) the dispute was about ownership of retired research chimpanzees. A Travis County probate court appointed a receiver for the chimpanzees. Id. at 631. However, the case on appeal was from a judgment of a Bexar County trial court in a separate proceeding. Id. at 630. The court of appeals recognized that "following the discharge of the receiver," the Travis County probate court issued a corrected order of dismissal with prejudice expressly stating it would "retain jurisdiction for purposes of winding up the affairs of the receivership." Id. at 633. The court of appeals stated the rule that a court's power over receivership property continues until either the court relinquishes its jurisdiction over the suit or the receiver is discharged and the property restored to the persons entitled to it. Id. Because the Travis County probate court expressly retained jurisdiction over the chimpanzees, the court of appeals concluded the Bexar County court lacked jurisdiction to resolve the dispute regarding ownership of the chimpanzees. Id.