Eric Branckaert v. Valerie Otou

CourtCourt of Appeals of Texas
DecidedAugust 11, 2011
Docket01-08-00637-CV
StatusPublished

This text of Eric Branckaert v. Valerie Otou (Eric Branckaert v. Valerie Otou) 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
Eric Branckaert v. Valerie Otou, (Tex. Ct. App. 2011).

Opinion

Opinion issued August 11, 2011.

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-08-00637-CV

———————————

eric branckaert, Appellant

V.

VALERIE OTOU, Appellee

On Appeal from the 312th District Court

Harris County, Texas

Trial Court Case No. 2006-17541

MEMORANDUM OPINION

Appellant, Eric Branckaert, appeals from the trial court’s order denying his motion for new trial after appellee, Valerie Otou, received a default judgment against him establishing parentage and assessing child support.  In eight issues, Branckaert contends that the trial court did not have personal jurisdiction over him, and, even if the trial court had jurisdiction, the court nevertheless abused its discretion by refusing to grant his motion for new trial. We reverse and remand.

Background

Otou filed suit in Harris County, Texas, on March 17, 2006 to establish a parent-child relationship between Branckaert, a resident of Rome, Italy, and Otou’s daughter, O.O.B.  After service of citation by publication, the court appointed an attorney ad litem to represent Branckaert.[1]  Branckaert’s appointed attorney filed an original answer on July 20, 2007, and a motion to dismiss for lack of jurisdiction and an unverified special appearance on August 14, 2007.  On the day he filed his motion to dismiss for lack of jurisdiction and special appearance, the court revoked the first attorney at litem’s appointment and appointed a second attorney ad litem to represent Branckaert. No hearing was ever held on Branckaert’s special appearance.

The matter was set for trial on February 4, 2008.  Rather than proceeding with the trial, the court issued an agreed order allowing Branckaert’s second appointed attorney to withdraw from the representation.  At that time, Branckaert’s newly retained counsel, Richard Tholstrup, filed a motion for continuance in which he argued that that a continuance was necessary because paternity testing had not been done in the case and Branckaert denied being O.O.B.’s father. The court granted the motion.  Trial was reset for March 24, and then postponed to April 7, 2008. On April 1, 2008, Branckaert’s counsel, Tholstrup, filed a motion to withdraw claiming an inability to “effectively communicate with [Branckaert] in a manner consistent with good attorney-client relations.” Tholstrup’s motion to withdraw included information about the April 7, 2008 trial date and stated that a copy of the motion had been delivered to Branckaert.    Tholstrup’s motion stated that, although Branckaert’s mailing address was unknown, he was generally reachable by email.

On April 7, 2008, the day of trial, the court first considered Tholstrup’s motion to withdraw.  Tholstrup’s associate, Christine Thrash, represented to the court that Branckaert had received a copy of the motion to withdraw, and that he had responded by e-mail acknowledging such receipt.  Otou’s counsel then had Thrash confirm on the record that Branckaert had been notified about the trial date.

The trial court then granted Tholstrup’s motion to withdraw and immediately proceeded to try the case on its merits, without Branckaert being present or represented by counsel.  At the trial, Otou testified that Branckaert was O.O.B’s father, and that no other man could possibly be the father.  Otou also testified about Branckaert’s employment, income, and lack of contact with O.O.B. In addition, Otou testified that the trial court had previously ordered a paternity test, but that Branckaert had failed to show up for the DNA test.

One week later, the court issued an order in which it adjudicated Branckaert to be the father of O.O.B., named Otou sole managing conservator of the child, denied Branckaert visitation, and ordered Branckaert to pay child support, attorney’s fees, and court costs. Thereafter, Branckaert retained a new attorney, Cheryl Alsandor, who filed a Motion for New Trial, which was denied after a hearing.  This appeal ensued.

Personal Jurisdiction

In his eighth issue on appeal, Branckaert argues that the trial court erred in not granting a new trial because it lacked personal jurisdiction over him.  Because this issue goes to jurisdiction, we address it first. 

Law Applicable to Special Appearances

Under Rule 120a, a special appearance, properly entered, enables a non-resident defendant to challenge personal jurisdiction in a Texas court. Tex. R. Civ. P. 120a.  Rule 120a requires strict compliance, and a non-resident defendant will be subject to personal jurisdiction in Texas courts if the defendant enters a general appearance. Morris v. Morris, 894 S.W.2d 859, 862 (Tex. App.—Fort Worth 1995, no writ); see also Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472 n.14, 105 S. Ct. 2174, 2182 n.14 (1985) (“[T]he personal jurisdiction requirement is a waivable right.”). Rule 120a states that “[e]very appearance, prior to judgment, not in compliance with this rule is a general appearance.” Tex. R. Civ. P. 120a(1); see also Kawasaki Steel Corp. v. Middleton, 699 S.W.2d 199, 201 (Tex. 1985).  In this appeal, we consider (1) whether Braenckaert properly filed a special appearance contesting jurisdiction, and, if he did, (2) whether he waived that special appearance by making a general appearance.

Did Unverified Special Appearance Adequately Contest Jurisdiction?

Rule 120a of the Texas Rules of Civil Procedure provides that a “special appearance shall be made by sworn motion . . .

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Burger King Corp. v. Rudzewicz
471 U.S. 462 (Supreme Court, 1985)
Cayton v. Moore
224 S.W.3d 440 (Court of Appeals of Texas, 2007)
Sims v. Fitzpatrick
288 S.W.3d 93 (Court of Appeals of Texas, 2009)
Dawson-Austin v. Austin
968 S.W.2d 319 (Texas Supreme Court, 1998)
Morris v. Morris
894 S.W.2d 859 (Court of Appeals of Texas, 1995)
Williams v. Bank One, Texas, N.A.
15 S.W.3d 110 (Court of Appeals of Texas, 1999)
Misium v. Misium
902 S.W.2d 195 (Court of Appeals of Texas, 1995)
Moss v. Malone
880 S.W.2d 45 (Court of Appeals of Texas, 1994)
Kawasaki Steel Corp. v. Middleton
699 S.W.2d 199 (Texas Supreme Court, 1985)
Fridl v. Cook
908 S.W.2d 507 (Court of Appeals of Texas, 1995)
Walker v. Packer
827 S.W.2d 833 (Texas Supreme Court, 1992)
Downer v. Aquamarine Operators, Inc.
701 S.W.2d 238 (Texas Supreme Court, 1985)
Moore Ex Rel. Moore v. Elektro-Mobil Technik GmbH
874 S.W.2d 324 (Court of Appeals of Texas, 1994)
John v. State
826 S.W.2d 138 (Texas Supreme Court, 1992)
Champion International Corp. v. Twelfth Court of Appeals
762 S.W.2d 898 (Texas Supreme Court, 1988)
In the Interest of R.R. & S.J.S.
209 S.W.3d 112 (Texas Supreme Court, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
Eric Branckaert v. Valerie Otou, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-branckaert-v-valerie-otou-texapp-2011.