Christopher Hughes v. Christina Hughes

Court of Appeals of Texas·Decided July 23, 2025·No. 04-24-00453-CV·Published

Opinion

Fourth Court of Appeals

San Antonio, Texas

MEMORANDUM OPINION

No. 04-24-00453-CV

Christopher HUGHES,

Appellant

v.

Christina HUGHES,

Appellee

From the 216th Judicial District Court, Kerr County, Texas Trial Court No. 22823A

Honorable Albert D. Pattillo, III, Judge Presiding

Opinion by: Adrian A. Spears II, Justice

Sitting: Rebeca C. Martinez, Chief Justice Irene Rios, Justice

Adrian A. Spears II, Justice

Delivered and Filed: July 23, 2025 AFFIRMED After a bench trial, the trial court signed a final decree of divorce appointing Christina Hughes and Christopher Hughes as joint managing conservators of their two young children, E.L.H. and G.L.H. The decree designated Christina as the joint managing conservator with the exclusive right to determine the children’s primary residence without geographic restriction. On appeal, Christopher argues the trial court abused its discretion by not imposing a geographic restriction on the children’s primary residence. We affirm.

BACKGROUND

Christina and Christopher were married on October 17, 2015. Their first child, E.L.H., was born in 2018. On December 4, 2022, Christopher told Christina he wanted a divorce and the couple separated. At the time, Christina was twenty-three weeks pregnant with G.L.H., who was not born until March 2023. Christina filed a petition for divorce on December 20, 2022, and Christopher filed a counterpetition on February 2, 2023.

Before the separation, Christina was a stay-at-home parent, and Christopher supported the family financially by working as a traveling nurse. Christopher was working and staying in Dallas, Texas, while Christina and E.L.H. were living in the marital home in Kerrville, Texas. Christina and E.L.H. would sometimes visit Christopher in Dallas, and Christopher would sometimes come home to Kerrville to visit Christina and E.L.H. After the separation, Christopher continued to work and live in Dallas. Meanwhile, Christina, E.L.H., and G.L.H. lived in the marital home in Kerrville, Texas.

On June 20, 2023, the trial court held an evidentiary hearing and rendered temporary orders. Both parents were appointed temporary joint managing conservators of the children. Christina was designated the temporary joint managing conservator with the exclusive right to determine the children’s primary residence with a geographic restriction limited to Kerr County and the contiguous counties. Christopher was ordered to pay $1,500.00 per month in temporary child support in accordance with the child support guidelines and $1,000.00 per month in temporary spousal support. Because Christopher resided more than one hundred miles from E.L.H., Christopher was given the right to possession of four-year-old E.L.H. for one weekend per month. Because G.L.H. was only three months old, Christopher was not given the right to overnight possession of G.L.H.; however, Christopher and Christina were ordered to work in good

faith with a parent facilitator to establish an increasing or “stair step” schedule for Christopher to have possession and access to G.L.H.

Final trial on the merits was held on March 18, 2024. At trial, Christina testified that since the separation she and the children had experienced financial difficulties. Christopher had failed to make multiple mortgage payments on the marital home and the home’s water was shut off due to nonpayment. Christina’s father had helped Christina and the children by making the mortgage payments for several months and buying necessary items for the children. After the marital home was sold, Christina and the children went to live with friends. By the time of trial, Christina was employed at a daycare center in Kerrville, where she was earning $13.75 an hour. Christina’s employer offered her a fifty-percent reduction on childcare, which helped her pay for E.L.H.’s daycare.

Christina explained that she was contemplating a move to Lexington, South Carolina, so she could earn a better living and better support the children. Christina had an aunt who lived in Lexington, and the aunt owned a large house with extra bedrooms and a one-bedroom, one-bath cottage on the property. The aunt, with whom Christina had a close relationship, had invited Christina and the children to come live with her rent free. The aunt had also offered to provide childcare for the children while Christina was at work. The aunt’s home was in a top school district. After researching the issue, Christina felt that her economic opportunities were better in Lexington than in Kerr County. Christina, who had a bachelor’s degree in science and public health, had already applied for two jobs in South Carolina. One of these jobs was an early interventionist/case manager, a field in which Christina had seven years’ experience. Both jobs would pay Christina more than she was making at her current job, increasing her annual salary by about $20,000 a year.

Christina testified that even if she and the children were allowed to relocate to South Carolina, the children would be able to maintain a relationship with Christopher. Christina presented evidence showing that two airlines offered roundtrip airfares between Dallas, Texas, and Charlotte, North Carolina for $123.00 or less. Christina believed that she and Christopher could afford this airfare and that it would be feasible for the children to have in-person visits with him. Additionally, Christina said that if they were allowed to move to South Carolina, she and the children would still return to Texas for visits with family and friends, which would provide additional opportunities for Christopher and the children to visit in person. Christina added that the children had daily electronic communications with Christopher, and they would continue to do so. Finally, Christina testified she had researched nursing jobs in South Carolina and the salary for these jobs was commensurate with the salary Christopher was now earning in Dallas.

Christina’s father, David Mauk, testified that after the couple separated, Christina and the children struggled without Christopher’s consistent financial support. During this time, Mauk had helped Christina and the children by making $7,976.08 in mortgage payments on the marital home and providing $18,800.24 in other economic support for Christina and the children. Christina’s friends had also helped Christina and the children during this difficult time. After the marital home was sold, some of her friends had welcomed Christina and the children into their home. In Mauk’s opinion, Christopher’s lack of support made it hard for Christina and the children to thrive in Kerrville. Even though it pained him to say so, Mauk felt that the economic and educational opportunities for Christina and the children were better in South Carolina than in Kerrville. Mauk was afraid that if Christina and the children continued to live in Kerrville, they would wind up economically disadvantaged.

Christopher testified that by the time of trial he was $9,000.00 in arrears on temporary child and spousal support, but he also said that on the morning of trial he paid $3,000.00 toward this arrearage. According to Christopher, these arrearages accrued because in addition to the temporary child and spousal support he had other bills to pay such as his rent, insurance, and cell phone bills. Christopher also mentioned that he had lost his job and was out of work for a month. Christopher acknowledged that after he and Christina separated, he made numerous discretionary purchases, including the purchase of a motorcycle. Christopher was currently living with his girlfriend in her home, where he paid for part of the cost of housing and groceries.

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