CROSSOVER: Dallas Court Upholds Civil Stalking Protective Order Based on Doxxing, Mass Harassment, and Threat-Facilitating Speech

Schubiner v. Julis, 05-24-00888-CV, May 26, 2026.

On appeal from 44th Judicial District Court, Dallas County, Texas

Synopsis

The Dallas Court of Appeals affirmed a Chapter 7B protective order based on an extended pattern of doxxing, mass emails and texts, social-media attacks, and recruitment of third parties to confront the protected parties in person. The court treated the respondent’s conduct as a repeated, targeted course of conduct that he knew or reasonably should have known would be regarded as threatening, harassing, alarming, abusing, tormenting, or embarrassing, and held the evidence legally and factually sufficient to support stalking findings and the resulting order.

Relevance to Family Law

Although Schubiner v. Julis arises out of a commercial dispute, its practical significance for Texas family lawyers is immediate. In divorce, SAPCR, and post-judgment enforcement litigation, parties increasingly weaponize digital platforms—mass emails to extended family, social-media campaigns, publication of home addresses, disclosure of school or event locations, and indirect contact through friends, employers, romantic partners, or children’s communities. This opinion confirms that Texas courts may evaluate those acts collectively as a stalking “course of conduct,” not as isolated speech events, and that a protective order can rest on digitally enabled harassment aimed at the opposing party and the party’s family. For family-law litigators, that matters in temporary-orders practice, child-safety arguments, injunction strategy, supervised possession disputes, relocation fights, and credibility determinations bearing on conservatorship.

Case Summary

Fact Summary

The appellees were high-profile business executives who had previously been adverse to the appellant in substantial lending and litigation matters. After the appellant failed in prior litigation, the record showed that he redirected his efforts toward the individuals themselves, their wives, families, colleagues, and professional network.

According to the opinion, the appellant registered a look-alike domain and used it to publish content attacking the appellees, their relatives, Canyon personnel, and outside counsel. The postings allegedly included false accusations of serious financial wrongdoing, suggestions that the appellees were connected to deaths of developers, and material implying they should be imprisoned. Most significantly for the stalking analysis, the appellant posted photographs and street addresses of personal residences alongside photographs of the appellees and their wives and urged members of the public to confront them at home. The court identified this as doxxing.

The record further showed mass electronic dissemination. The appellant testified that his communications were sent to more than 10,000 email addresses assembled through hired online workers, and that the recipients were not voluntary subscribers. The list included the appellees, family members, coworkers, and business associates. The harassment extended beyond email. The opinion recounts text messages directed to wives and children, harassment through social-media accounts including fake accounts, and the transformation of website content into self-published books marketed with the appellees’ images and then promoted through mass email campaigns.

The conduct also crossed from online publication into real-world confrontation. The appellant recruited and paid strangers through Craigslist to trespass and distribute his book at a private event where one appellee was scheduled to speak, and later threatened comparable disruptions at other events. Even after suit was filed, the conduct allegedly continued, including mass-blasted emails identifying hearing dates, announcing where appellees would testify, posting photographs of counsel, and threatening bar complaints. The trial court entered a five-year protective order prohibiting direct or indirect communications, dissemination of addresses and contact information, going near residences, workplaces, or schools, disclosing whereabouts, stalking conduct, and evasion through third parties or entities. The Dallas Court affirmed.

Issues Decided

• Whether legally and factually sufficient evidence supported the finding that the appellant violated the Texas stalking statute and thus supported entry of a protective order under Chapter 7B of the Texas Code of Criminal Procedure.

• Whether repeated online postings, doxxing, mass emails, texts, social-media harassment, and indirect contact through third parties could constitute a course of conduct reasonably likely to harass, alarm, abuse, torment, or embarrass under the stalking framework.

• Whether the terms of the protective order were unconstitutionally vague or overbroad.

• Whether the protective order operated as an unconstitutional prior restraint on speech.

Rules Applied

The opinion proceeds under Texas Code of Criminal Procedure Chapter 7B, which authorizes protective orders for certain victims, including where stalking is shown. The court also relied on the Texas stalking framework requiring proof of a repeated course of conduct directed at another person that the actor knows or reasonably should know the other person will regard as threatening specified harms or as placing the person, family, or household in fear of bodily injury or death, and that would cause a reasonable person to feel similarly and actually cause that response.

From the snippet provided, the court expressly framed review under legal- and factual-sufficiency standards applicable to protective-order appeals. In substance, the court treated the following principles as controlling:

• A stalking determination may rest on a pattern of conduct rather than any single act viewed in isolation.

• Conduct directed not only at the principal targets but also at spouses, children, relatives, and closely connected associates can be relevant to the stalking analysis.

• Digital conduct—doxxing, repeated electronic messages, social-media posting, and wide dissemination of personal information—can qualify as actionable conduct, especially when combined with efforts to induce real-world confrontation.

• The respondent’s use of intermediaries does not insulate him; directing, encouraging, hiring, or causing others to engage in confrontational conduct remains part of the prohibited course of conduct.

• Protective orders may be tailored to prevent recurrence of the specific conduct proved at hearing, including indirect communication, disclosure of whereabouts, and publication of sensitive identifying information.

The opinion also addressed constitutional objections grounded in vagueness, overbreadth, and prior restraint. While the excerpt does not include the full constitutional analysis, the affirmance indicates the court concluded the order tracked the proven misconduct closely enough to survive those challenges.

Application

The Dallas Court approached the case as one about cumulative, targeted behavior, not merely offensive publications or criticism. That framing is the key analytical move. The appellant attempted to characterize his actions as speech related to a business dispute. The court instead looked at the record as a sustained campaign directed at identifiable people and their families, executed across multiple channels, and designed to maximize pressure, humiliation, exposure, and confrontation.

The doxxing evidence mattered because it converted speech into threat-facilitating conduct. Posting home photographs and street addresses beside family images, while inviting members of the public to confront the targets at their residences, gave the trial court a concrete basis to find conduct the actor knew or should have known would be regarded as threatening, harassing, alarming, tormenting, or embarrassing. The mass-email evidence mattered because it showed repetition, breadth, and deliberateness. This was not a one-off communication to a closed audience; it was a mass campaign aimed at the appellees’ business and personal ecosystems, without meaningful opt-in consent and with ineffective unsubscribe mechanisms.

The third-party recruitment evidence was especially powerful. By paying strangers to intrude on a private event and distribute accusatory materials where one appellee was speaking, the appellant demonstrated that his campaign was not confined to online criticism. The threats to repeat this conduct at future events reinforced the trial court’s conclusion that the behavior was ongoing and likely to continue absent injunctive restraint. The continued dissemination of hearing information, event locations, and attacks on spouses after litigation began further undercut any argument that the conduct was accidental, stale, or misunderstood.

In affirming, the court effectively recognized that modern stalking can be digitally mediated. The legal significance lay not only in the content of the speech but in the pattern: repeated targeting, exposure of personal-location information, pressure through families and associates, use of aliases and affiliated entities, and recruitment of outsiders to create in-person encounters. On that record, the evidence was both legally and factually sufficient.

Holding

The court held that the evidence was legally and factually sufficient to support the trial court’s finding that the appellant engaged in stalking under the governing statute and that a Chapter 7B protective order was therefore proper. The record showed a repeated course of conduct directed at the appellees and their families, including doxxing, mass-distributed emails and texts, social-media harassment, and inducement of third parties to confront them at events. The court concluded that such conduct could reasonably be found to be conduct the appellant knew or should have known would be regarded as threatening, harassing, alarming, abusing, tormenting, or embarrassing.

The court also rejected the appellant’s constitutional attacks on the order. Although the full reasoning is not reproduced in the excerpt, the affirmance means the court found the order sufficiently definite, not impermissibly overbroad in relation to the proven conduct, and not an unconstitutional prior restraint under the circumstances presented. In other words, where the evidentiary record shows targeted harassment and stalking behavior rather than mere protected commentary, a carefully framed order restricting direct and indirect contact, dissemination of personal information, and threat-facilitating conduct will stand.

Practical Application

For family lawyers, the principal lesson is that Chapter 7B-type stalking analysis can become central whenever one party uses litigation-adjacent harassment to gain leverage. In divorce cases, this may look like publishing the other spouse’s home address, employer details, or affair allegations to friends, school communities, church groups, or business contacts. In custody cases, it may involve repeated texts to the co-parent’s new partner, social-media posts identifying the child’s school or extracurricular schedule, or recruiting relatives and mutual friends to confront the opposing parent at exchanges or games. In property disputes, one spouse may try to force settlement by embarrassing the other through mass emails to investors, clients, or professional boards. Schubiner gives trial counsel a framework for arguing that these are not merely ugly litigation tactics; taken together, they may establish a statutory course of conduct supporting protective relief.

Practitioners should also think structurally about proof. The winning case here appears to have been built by showing continuity, targeting, escalation, and foreseeability. That same approach works in family court. Preserve screenshots, export metadata, identify recipients, prove the absence of consent or subscription, connect aliases or shell entities to the actor, and document in-person consequences such as school alerts, event disruptions, security changes, or emotional impact on children. Do not treat each act as a separate skirmish. Build the narrative of a campaign.

For the defense side, the case is a warning that “I was just speaking publicly” is often insufficient where the evidence shows repetitive targeting, publication of private-location information, indirect contact through family and associates, and use of others to create physical confrontations. In family cases especially, litigants can unintentionally move from aggressive advocacy into stalking territory by posting hearing dates, courthouse appearances, school locations, or residential information, or by encouraging online followers or relatives to “show up” and “ask questions.”

Checklists

Building a Stalking-Protective-Order Record in Family Court

• Identify every communication channel used: email, text, Facebook, Instagram, X, LinkedIn, TikTok, blogs, websites, burner numbers, and messaging apps.

• Create a chronology showing repetition, escalation, and clustering around hearings, exchanges, mediation, school events, or possession periods.

• Preserve screenshots with visible dates, usernames, URLs, and recipient information.

• Gather evidence of doxxing, including publication of home addresses, school locations, work addresses, vehicle details, or event schedules.

• Document indirect targeting of spouses, children, new partners, grandparents, employers, teachers, therapists, coaches, or religious communities.

• Prove third-party recruitment: messages urging others to contact, confront, monitor, photograph, or appear near the protected persons.

• Show actual impact, including changed routines, missed events, security measures, school notifications, emotional distress, or fear of confrontation.

• Tie fake accounts, shell entities, or affiliated websites back to the respondent through registration records, payment records, IP evidence, testimony, or stylistic overlap.

Drafting a Protective Order That Will Better Survive Appeal

• Track the language of the statute and the evidence proved at hearing.

• Define the protected persons with enough specificity to avoid avoidable vagueness challenges.

• Include direct and indirect communications if the record shows use of intermediaries.

• Address publication of addresses, contact information, and present or future whereabouts if doxxing or event-targeting was proved.

• Include no-go zones for residence, workplace, school, and regular child-exchange locations when the record supports them.

• Include anti-evasion language covering agents, affiliates, shell entities, and encouraged third parties.

• Build exceptions carefully where truly necessary, such as communication through counsel or court-ordered platforms.

• Make a robust evidentiary record on why the order’s scope matches the demonstrated pattern of conduct.

Using Schubiner in Divorce and Custody Litigation

• Cite the case when the opposing party claims online harassment is merely “speech” rather than conduct.

• Frame the problem as a cumulative course of conduct, not a set of disconnected posts or texts.

• Emphasize harm to family members, not just the named litigant, where spouses or children are being targeted.

• Use the case to support temporary restraining orders, temporary injunctions, and protective orders when event-location disclosures or home-address publication increase safety risks.

• In conservatorship disputes, argue that harassment of the other parent, the child’s school, or the child’s household bears directly on best-interest and co-parenting capacity.

• In modification cases, use persistent digital harassment to support material-and-substantial-change arguments where safety, stability, or communication has deteriorated.

Avoiding the Downside if You Represent the Accused Litigant

• Instruct the client immediately to stop posting about the opposing party, the children, the other household, and the case.

• Prohibit publication of addresses, school names, event details, work locations, or photographs that reveal location information.

• Do not permit contact through friends, relatives, investigators, new partners, or online followers.

• Stop mass-email or mass-text campaigns to family, employers, school communities, churches, or business associates.

• Preserve evidence but avoid “counterpublication” that republishes the protected party’s information.

• Route all necessary communications through counsel or court-approved platforms.

• Audit aliases, alternate accounts, websites, and business entities for content that could be attributed to the client.

• Prepare for the constitutional defense realistically; if the facts show targeted harassment and third-party facilitation, a pure free-speech framing may fail.

Citation

Schubiner v. Julis, No. 05-24-00888-CV, 2026 WL ___ (Tex. App.—Dallas May 26, 2026, no pet.) (mem. op.).

Full Opinion

Read the full opinion here

Family Law Crossover

This is the kind of civil opinion that can be weaponized effectively in Texas divorce and custody litigation because it validates a familiar fact pattern: one litigant tries to dominate the case outside the courthouse by humiliating, exposing, or swarming the other party through digital means. If you represent the targeted spouse or parent, Schubiner is useful authority for reframing “online drama” as evidence of stalking conduct, coercive control, poor judgment, and danger to the family’s stability. It can support emergency relief, tailored non-disclosure provisions, restrictions on indirect contact, and arguments that the offending party cannot be trusted to respect boundaries around the child, the child’s school, or the other parent’s home.

The opinion is equally important offensively in conservatorship litigation because it helps connect harassment of the other parent with child-centered best-interest concerns. A parent who mass-disseminates accusations, reveals addresses, publicizes event attendance, or recruits others to appear at school or extracurricular activities creates instability and foreseeable risk for the child. That conduct can be marshaled not only for protective relief but also for restrictions on possession exchanges, supervised communication protocols, limits on social-media posting about the child, and findings that the parent lacks the judgment necessary for joint decision-making. In short, Schubiner gives family lawyers a modern appellate vocabulary for converting digitally enabled intimidation into concrete, court-remediable misconduct.

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