The Houston First District Court of Appeals has held that an order for temporary injunction must be supported by pleading.

In Easton v. Brasch, the Eastons filed suit against Brasch and filed pleadings for a temporary restraining order, a temporary injunction, and a permanent injunction.  After a hearing on the temporary injunction, the trial court rendered a mutual injunction that was binding on both Michael Easton and Brian Brasch.  The Eastons filed an interlocutory appeal and complained that the trial court had abused its discretion because the injunction in favor of Brasch was not supported by a pleading verified by affidavit.  The appellate court agreed, noting that Civil Procedure Rule 682 requires the existence of a pleading verified by affidavit.  The Court’s opinion may be found here.