Anne Moreland Dorai v. Suri Dorai

CourtCourt of Appeals of Texas
DecidedApril 18, 2013
Docket01-12-00308-CV
StatusPublished

This text of Anne Moreland Dorai v. Suri Dorai (Anne Moreland Dorai v. Suri Dorai) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anne Moreland Dorai v. Suri Dorai, (Tex. Ct. App. 2013).

Opinion

Opinion issued April 18, 2013

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-12-00308-CV ——————————— ANNE MORELAND DORAI, Appellant V. SURI DORAI, Appellee

On Appeal from the 387th District Court Fort Bend County, Texas Trial Court Case No. 11-DCV-190567

MEMORANDUM OPINION

Anne Moreland Morai appeals from a decree of divorce dissolving the

marriage between her and Suri Dorai. In four issues, Anne argues the trial court

(1) erred by mischaracterizing certain property as Suri’s separate property, (2) abused its discretion by denying her motion for new trial, (3) abused its discretion

by assigning Suri the responsibility of designating their child’s primary residence,

and (4) abused its discretion by denying her motion for continuance. Suri

requested in a motion that we dismiss the appeal under the acceptance of the

benefits doctrine.

We dismiss as moot Anne’s first, second, and fourth issues. We further

affirm the judgment of the trial court.

Background

Anne and Suri were married on March 23, 2004. They had one child. On

June 9, 2011, Suri filed a petition for divorce. Anne answered and filed a counter-

petition for divorce. The parties went to trial on January 10, 2012. The trial court

issued its final decree of divorce about two weeks later.

At trial, Suri requested a joint conservatorship with Anne having the right to

designate the child’s primary residence. Anne requested sole managing

conservatorship. During the trial, the trial court expressed concerns about

assigning Anne the right to designate the child’s primary residence. Suri admitted

that he felt conflicted about his request for Anne to make the determination, but

ultimately stood by his request. In the judgment, the trial court assigned Suri and

Anne as joint conservators of their child with Suri having the right to designate the

child’s primary residence.

2 Later that year, after Anne had filed her notice of appeal, the trial court

signed an order requested by the parties concerning conveyance of title in their two

homes. The order explains that, at a hearing on a number of motions, the parties

had reached an agreement on the disposition of two homes acquired during the

marriage; that the order reflected the agreement of the parties; and that the parties

requested the trial court to enter the agreement as an order of the court. The order

required Suri to “execute a Special Warranty Deed conveying all rights, title and

interest” in their Maryland home to Anne. It further required Suri to execute any

further deeds if the special warranty deed was insufficient to convey full title in the

home to Anne. The order required the conveyance to be completed on the date the

order was signed.

Acceptance of the Benefits

Under the acceptance of the benefits doctrine, “[a] litigant cannot treat a

judgment as both right and wrong, and if he has voluntarily accepted the benefits

of a judgment, he cannot afterward prosecute an appeal therefrom.” Carle v.

Carle, 234 S.W.2d 1002, 1004 (Tex. 1950). “The doctrine arises most often in

divorce cases in which one spouse accepts certain assets awarded by the judgment

and then seeks to appeal the remainder of the judgment.” Williams v. LifeCare

Hosps. of N. Tex., 207 S.W.3d 828, 830 (Tex. App.—Fort Worth 2006, no pet.). If

he accepts the benefits of a judgment, a party is estopped from challenging that

3 judgment on appeal. Waite v. Waite, 150 S.W.3d 797, 803 (Tex. App.—Houston

[14th Dist.] 2004, pet. denied). In that event, the appeal is rendered moot and must

be dismissed. Harlow Land Co., Ltd. v. City of Melissa, 314 S.W.3d 713, 716

(Tex. App.—Dallas 2010, no pet.).

The appellee bears the burden of proof to establish application of the

acceptance of the benefits doctrine. Richards v. Richards, 371 S.W.3d 412, 414

(Tex. App.—Houston [1st Dist.] 2012, no pet.). The parties may rely on affidavits

and other satisfactory evidence to establish whether the appellate court retains

jurisdiction over the appeal. See id. (citing TEX. GOV’T CODE ANN. § 22.220(c)

(Vernon Supp. 2011); TEX. R. APP. P. 10.2).

An appellant may avoid the application of the acceptance of the benefits

doctrine by showing the application of either of two exceptions: (1) acceptance of

the benefits of the judgment was a result of financial duress or other economic

circumstances or (2) reversal of the judgment on the grounds appealed could not

possibly affect the appellant’s right to benefits accepted. Williams, 207 S.W.3d at

830; Waite, 150 S.W.3d at 803–04. These exceptions are narrow. Waite, 150

S.W.3d at 804. The appellant bears the burden of establishing the application of

the exceptions. Richards, 371 S.W.3d at 415.

One of the bases that Suri presents for establishing that Anne has accepted

the benefits of the bargain is that Anne has taken legal possession of the home

4 awarded to her in the divorce. On January 4, 2013, the trial court signed an order

requested by the parties. The order explains that, at a hearing on a number of

motions, the parties had reached an agreement on the disposition of two homes

acquired during the marriage; that the order reflected the agreement of the parties;

and that the parties requested the trial court to enter the agreement as an order of

the court. The order required Suri to “execute a Special Warranty Deed conveying

all rights, title and interest” in their Maryland home to Anne. It further required

Suri to execute any further deeds if the special warranty deed was insufficient to

convey full title in the home to Anne. The order required the conveyance to be

completed on the date the order was signed.

A party to a judgment accepts the benefits of the judgment when she seeks

and obtains legal title to real property awarded in the judgment. See Waite, 150

S.W.3d at 804. Accordingly, we hold that Suri has met his burden of establishing

that Anne accepted the benefits of the judgment.

Anne did not respond to Suri’s argument that she had accepted the benefits

of the judgment. Accordingly, no grounds have been presented for considering

whether Anne meets any of the available exceptions.

Typically, accepting the benefits of a judgment moots the entire appeal. See

Carle, 234 S.W.2d at 1004 (holding “[a] litigant cannot treat a judgment as both

right and wrong, and if he has voluntarily accepted the benefits of a judgment, he

5 cannot afterward prosecute an appeal therefrom”); Harlow Land Co., 314 S.W.3d

at 716 (holding “[i]f the [acceptance of the benefits] doctrine applies, the appeal is

rendered moot, and the proper disposition is dismissal”). This is not always the

case, however. See, e.g., Tomsu v. Tomsu, 381 S.W.3d 715, 717 (Tex. App.—

Beaumont 2012, no pet.) (holding acceptance of benefits doctrine applied and

continuing to analyze issue concerning spousal maintenance).

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Related

Waite v. Waite
150 S.W.3d 797 (Court of Appeals of Texas, 2004)
Harlow Land Co., Ltd. v. City of Melissa
314 S.W.3d 713 (Court of Appeals of Texas, 2010)
Leithold v. Plass
413 S.W.2d 698 (Texas Supreme Court, 1967)
Carle v. Carle
234 S.W.2d 1002 (Texas Supreme Court, 1950)
Worford v. Stamper
801 S.W.2d 108 (Texas Supreme Court, 1991)
Dupree v. Texas Department of Protective & Regulatory Services
907 S.W.2d 81 (Court of Appeals of Texas, 1995)
Dennis v. Smith
962 S.W.2d 67 (Court of Appeals of Texas, 1998)
Williams v. LifeCare Hospitals of North Texas, L.P.
207 S.W.3d 828 (Court of Appeals of Texas, 2006)
Holley v. Holley
864 S.W.2d 703 (Court of Appeals of Texas, 1993)
in the Interest of K.R.P., a Child
80 S.W.3d 669 (Court of Appeals of Texas, 2002)
James Alexander Richards v. Karen Sue Richards
371 S.W.3d 412 (Court of Appeals of Texas, 2012)
In the Interest of J.A.J.
243 S.W.3d 611 (Texas Supreme Court, 2007)
In the Interest of K.L.W.
301 S.W.3d 423 (Court of Appeals of Texas, 2009)
Tomsu v. Tomsu
381 S.W.3d 715 (Court of Appeals of Texas, 2012)

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