Limitations on the enforcement of “voluntary” spousal support obligations

Dalton v. Dalton, 551 S.W.3d 126 (Tex. 2018) Link to Court’s Opinion Facts  Husband and wife entered an agreement in Oklahoma for spousal support, which an Oklahoma court approved.  Husband later filed for divorce in Texas.  The Texas court gave the Oklahoma order full faith and credit.  The court then granted the divorce, incorporating the parties’ agreements as approved in […]

Whether a memo order from the court is a “final order” for appellate deadline purposes

In the Interest of R.R.K. (Tex. 2019) (No. 18-0273) Link the Court’s Opinion Facts:  Following a bench trial, the court issued a one-page memorandum with its ruling.  It contained a Mother Hubbard clause denying all relief not expressly granted but lacked information required by Family Code 105.006.  Both parties prepared final orders for entry, and the trial court later signed […]

Enforcement of a Mediated Settlement Agreement Signed Before the Divorce Was Filed

Highsmith v. Highsmith (Tex. 2019) (18-0262) Facts: Husband and wife signed a Mediated Settlement Agreement (“MSA”) before filing for divorce. Husband later filed a divorce petition. He subsequently proved up the divorce and had judgment rendered on the MSA. Wife filed a motion for new trial. She asserted that the MSA did not meet the Family Code’s requirements because it […]