Eric John Ramirez v. Juanita Sanchez

CourtCourt of Appeals of Texas
DecidedApril 13, 2023
Docket01-21-00417-CV
StatusPublished

This text of Eric John Ramirez v. Juanita Sanchez (Eric John Ramirez v. Juanita Sanchez) 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 John Ramirez v. Juanita Sanchez, (Tex. Ct. App. 2023).

Opinion

Opinion issued April 13, 2023

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-21-00417-CV ——————————— ERIC JOHN RAMIREZ, Appellant V. JUANITA SANCHEZ, Appellee

On Appeal from the 308th District Court Harris County, Texas Trial Court Case No. 2013-21465

MEMORANDUM OPINION

This appeal arises from a suit affecting the parent-child relationship. In 2013,

the trial court issued an order (the “2013 Order”) appointing appellant Eric John

Ramirez and appellee Juanita Sanchez as the joint managing conservators of their minor child, A.J.R. The trial court granted Sanchez the exclusive right to designate

the child’s primary residence and ordered Ramirez to pay child support.

In 2019, Ramirez filed the instant suit seeking to modify the 2013 Order. He

requested either sole managing conservatorship of A.J.R. or the exclusive right to

designate his primary residence, along with child support. Ramirez also filed a

motion for enforcement alleging that Sanchez had interfered with his periods of

possession and access to the child. The trial court dismissed that motion.

Sanchez moved for a no-evidence summary judgment on Ramirez’s claims—

which the trial court granted. Sanchez also filed a counterpetition for modification

seeking to increase Ramirez’s child support. After a bench trial on Sanchez’s

counterpetition, the trial court increased Ramirez’s child support.

Ramirez now appeals. In nine issues, Ramirez contends that the trial court

erred in granting a no-evidence summary judgment on his claims, in increasing his

child support, in admitting evidence, in granting injunctive relief, awarding

attorney’s fees, and assessing costs. Ramirez also complains of the trial court’s order

dismissing his motion for enforcement.

We reverse and remand in part and dismiss in part.

Background

In Ramirez’s petition to modify the 2013 Order, he asserted, as pertinent here,

that the “circumstances of [A.J.R.], a conservator, or other party affected by the order

2 to be modified [had] materially and substantially changed” since the rendition of the

2013 Order. Ramirez sought sole managing conservatorship of A.J.R. or the

exclusive right, as a joint managing conservator, to designate A.J.R.’s primary

residence. Ramirez also sought child support, an order modifying the terms and

conditions of possession, and injunctive relief.

Sanchez likewise asserted in her Second Amended Counterpetition that the

“financial circumstances and needs of [A.J.R.] or a person affected by the order [had]

materially and substantially changed” since the rendition of the 2013 Order. She

asserted that Ramirez’s child-support obligation was no longer in compliance with

the guidelines in Chapter 154 of the Texas Family Code and sought an increase in

Ramirez’s child support. Sanchez also sought orders regarding the possession and

transfer of A.J.R.’s passport, and injunctive relief.

On April 13, 2021, Sanchez filed a motion for no-evidence summary

judgment. She claimed that Ramirez “ha[d] produced no evidence to support his

contention that . . . [t]he circumstances of the child, [Ramirez], [Sanchez], or a party

affected by the order to be modified [had] materially and substantially changed since

the date or rendition of the order to be modified.”

Sanchez also claimed there was no evidence that it was in the best interest of

the child to modify conservatorship, to order Sanchez to pay child support, or to

modify the location of exchanges. Sanchez attached Ramirez’s discovery responses

3 as evidence to her no-evidence motion. She also included a notice that the

no-evidence motion would be heard by submission on May 4, 2021.

On April 21, 2021, Sanchez filed a Notice of Filing Amended Exhibits to [her]

Motion for Summary Judgment stating that Exhibits B and C to her motion were

“inadvertently filed with missing pages.”

Contemporaneously, Sanchez filed a Notice of Business Records Affidavit, to

which she attached the affidavit of Mitch Findley, a customer support manager for

the Our Family Wizard website, and 96 pages of messages between Sanchez and

Ramirez, along with journal entries by Sanchez.

Sanchez also filed a second Notice of Business Records Affidavit that

included the affidavit of Barbara Lynch Schnack, an employee of the Harris County

Domestic Relations Office, and a Child Custody Evaluation Report involving A.J.R.

In response to the no-evidence motion for summary judgment, Ramirez filed

a document entitled “Child Modification in the Best Interest of [A.J.R.].” In that

document, Ramirez presented facts about his relationship with Sanchez and with

A.J.R., facts about the current status of their relationships, and the basis for his

petition to modify conservatorship or the right to designate the child’s primary

residence. Ramirez did not attach any evidence.

The trial court granted Sanchez’s motion for no-evidence summary judgment.

The trial court stated in the summary judgment that it considered “the motion, any

4 response thereto, and . . . any evidence.” It also ordered Ramirez to pay Sanchez’s

attorney’s fees of $10,850.00 and costs.

A bench trial was subsequently held on Sanchez’s counterpetition to increase

Ramirez’s child support. Ramirez testified that, at the time of the 2013 Order, he

was a student with $1,404.65 in net monthly resources and was ordered to pay

$248.00 in monthly child support. Ramirez further testified that, since that time, his

financial circumstances had improved. He owned a company from which he

received a salary. Ramirez admitted that he transferred funds between his personal

and business accounts and that he paid personal expenses from the business account.

The trial court thus ruled that it would consider both the business income and

Ramirez’s salary in setting his child support payments. Together they totaled

$13,229.08 in net monthly resources. The trial court admitted into evidence copies

of Ramirez’s financial statements.

Sanchez testified that, at the time of the 2013 Order, Ramirez was supporting

two children, and A.J.R. was three years old. At the time of the bench trial,

Ramirez’s income had increased, and his other child was no longer a minor. A.J.R.

was then eleven years old and had increased needs and expenses for tutoring and

sports.

At the conclusion of the bench trial, the trial court signed a Final Order in Suit

to Modify the Parent-Child Relationship (“Final Order”) on August 27, 2021. The

5 trial court ruled that “the circumstances of the child, a conservator, or other party

affected by the [2013 Order] ha[d] materially and substantially changed” since its

rendition and that Ramirez must pay Sanchez monthly child support in the amount

of $1,840.00, her attorney’s fees of $2,082.50, and costs.

In support of its Final Order, the trial court issued findings of fact and

conclusions of law. They state in pertinent part:

b. The Court finds that the financial circumstances and needs of the child have materially and substantially changed since the date of the order to be modified in that the child is now eight years older. At the time of the first order the child was only three years old. The Court heard testimony about current child related expenses including tutoring, extracurricular activities and sports. c.

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