Craig P. Longhurst v. Linda K. Clark

CourtCourt of Appeals of Texas
DecidedAugust 21, 2008
Docket01-07-00226-CV
StatusPublished

This text of Craig P. Longhurst v. Linda K. Clark (Craig P. Longhurst v. Linda K. Clark) 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
Craig P. Longhurst v. Linda K. Clark, (Tex. Ct. App. 2008).

Opinion

Opinion issued August 21, 2008



In The

Court of Appeals

For The

First District of Texas


NO. 01-07-00226-CV

  __________

CRAIG P. LONGHURST, Appellant

V.

LINDA K. CLARK, Appellee


On Appeal from the 257th District Court

Harris County, Texas

Trial Court Cause No. 1992-03711


MEMORANDUM OPINION

          In 2006, Linda K. Clark filed an amended motion requesting that the trial court render judgment against her former husband, Craig P. Longhurst, for previously confirmed and unconfirmed child support arrearages, plus interest, owed under the trial court’s 1992 order. The trial court granted Linda’s motion and rendered a cumulative judgment against Craig. On appeal, Craig challenges the trial court’s judgment in seven issues. We modify that part of the trial court’s judgment granting a cumulative judgment in Linda’s favor and affirm the judgment as modified.Background

          In 1988, Linda and Craig were divorced in Colorado. The Colorado court entered a child support order and granted Linda custody of the couple’s five minor children. Following the divorce, Linda and the children moved to Utah and Craig moved to Texas. In 1992, at the request of the State of Utah, the Attorney General of Texas brought a notice of registration and motion to enforce the Colorado child support order in Texas. The 257th District Court of Harris County entered a default order against Craig. In that order, the court rendered a judgment confirming that Craig owed $121,902.00 in arrearages. The court also modified Craig’s support obligations, ordering him to make monthly payments of $1,642.00 from May 1992 until all of the children were 18 years old, or later if any child over 18 was still enrolled in a program leading toward a high school diploma.

          In 2004, Linda filed a motion against Craig and the State of Texas to revive and enforce the 1992 judgment and to confirm all unpaid child support arrearages owed by Craig. The Attorney General filed a motion asking that the State of Texas be dismissed as a party. The court entered another default judgment against Craig and dismissed all of Linda’s claims against the State of Texas. Craig filed a motion for new trial, which the court granted.

          In 2006, Craig filed his original answer. After Linda filed an amended motion to revive and enforce the 1992 judgment and to confirm all unpaid child support arrearages, Craig filed an untimely response, which was struck. During the bench trial, Craig sought to introduce evidence of a 1993 child support order issued by the State of Utah and evidence that he had made payments pursuant to that order. The trial court excluded the evidence, and, following trial, rendered a cumulative judgment against Craig for $464,796.00, inclusive of interest. The court made findings of fact and conclusions of law upon Craig’s request. Craig filed a motion for new trial and requested additional and amended findings of fact and conclusions of law. The trial court denied Craig’s motion for new trial and request for additional and amended findings. Craig now appeals.

Standing

We begin with Craigs sixth issue, in which he contends that the trial court erred in granting Lindas motion because she lacked standing to enforce the 1992 Texas order.

Because standing is a component of subject-matter jurisdiction, we review a trial courts determination of standing de novo. Phillips v. Phillips, 244 S.W.3d 433, 435 (Tex. App.Houston [1st Dist.] 2007, no pet.). Standing may be raised for the first time on appeal. Austin Nursing Center, Inc. v. Lovato, 171 S.W.3d 845, 849 (Tex. 2005). In analyzing issues of standing, we determine whether a party has a sufficient relationship with the lawsuit so as to have a justiciable interest in its outcome. Id. at 848. In Texas, the standing doctrine requires that there be (1) a real controversy between the parties, that (2) will be actually determined by the judicial declaration sought. Id. at 849. We construe the petition in favor of the plaintiff and review the entire record to determine whether any evidence supports standing. Tex. Assn of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 446 (Tex. 1993).

In order to enforce Craigs support obligations across state lines, Linda utilized the Revised Uniform Reciprocal Enforcement of Support Act (RURESA). It appears from the record that Linda assigned her rights to receive child support under the Colorado order to the State of Utah, which in turn requested that the State of Texas enforce the order against Craig. The Texas Attorney General then brought a motion to register and enforce the Colorado order on Lindas behalf.

Craig asserts that, pursuant to statute, an application to the Attorney

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Craig P. Longhurst v. Linda K. Clark, Counsel Stack Legal Research, https://law.counselstack.com/opinion/craig-p-longhurst-v-linda-k-clark-texapp-2008.