Eric Leonard Tucker v. Natalia Citalli Covarrubias Campos

CourtCourt of Appeals of Texas
DecidedAugust 13, 2021
Docket03-20-00515-CV
StatusPublished

This text of Eric Leonard Tucker v. Natalia Citalli Covarrubias Campos (Eric Leonard Tucker v. Natalia Citalli Covarrubias Campos) 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 Leonard Tucker v. Natalia Citalli Covarrubias Campos, (Tex. Ct. App. 2021).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-20-00515-CV

Eric Leonard Tucker, Appellant

v.

Natalia Citlalli Covarrubias Campos, Appellee

FROM THE 98TH DISTRICT COURT OF TRAVIS COUNTY NO. D-1-FM-20-002135, THE HONORABLE DUSTIN M. HOWELL, JUDGE PRESIDING

MEMORANDUM OPINION

Eric Leonard Tucker appeals from the district court’s order finding that the

registration of a foreign child custody determination—the “Provisional Custody Decree rendered

by Mexican court on May 14, 2020” (the Mexican Order)—was valid. On appeal, Tucker

challenges the district court’s order on the ground that he did not have notice or an opportunity to

be heard in the Mexico proceeding before the Mexican Order was issued. For the following

reasons, we affirm the district court’s order.

BACKGROUND

Registration of Foreign Child Custody Determination

To give context to the parties’ dispute concerning the registration of the Mexican

Order, we briefly outline relevant statutory provisions. In this case, the parties agree that the

Mexican Order is a “child custody determination” as defined in the Uniform Child Custody Jurisdiction and Enforcement Act (the Act). See Tex. Fam. Code § 152.102(3) (defining “child

custody determination” as “judgment, decree, or other order of a court providing for legal

custody, physical custody, or visitation with respect to a child,” including temporary and initial

orders), (8) (defining “initial determination” as “the first child custody determination concerning

a particular child”).

As a child custody determination, the Mexican Order is treated under the Act as

having been issued by a court of another state. Id. § 152.105(a) (stating that state courts should

treat foreign country as if it were state of United States), (b) (providing generally that child

custody determination made in foreign country “must be recognized and enforced”). “A child

custody determination issued by a court of another state may be registered in this state, with or

without a simultaneous request for enforcement[,]” by sending documentation to the appropriate

Texas state court. Id. § 152.305(a); see Razo v. Vargas, 355 S.W.3d 866, 870–71 (Tex. App.—

Houston [1st Dist.] 2011, no pet.) (describing procedure for registering foreign judgment under

section 152.305 of Family Code).

After receiving the required documents to register the child custody

determination, the Texas state court files the determination as a foreign judgment and provides

notice to specified persons and an opportunity to contest the determination’s registration.

See Tex. Fam. Code § 152.305(b) (requiring court to cause determination to be filed with

accompanying documents and to serve notice upon specified persons), (c)(2) (requiring request

for hearing to contest registration to be made within 20 days after service of notice). At a contest

hearing, the court must confirm the validity of the registered order unless the person contesting

its registration establishes: (i) the issuing court did not have jurisdiction; (ii) the order has been

vacated, stayed, or modified by a court having jurisdiction to do so; or (iii) “the person

2 contesting registration was entitled to notice, but notice was not given in accordance with the

standards of Section 152.108, in the proceedings before the court that issued the order for which

registration is sought.” See id. § 152.305(d); see also id. § 152.108 (providing standard for

notice to persons outside state).

With this statutory framework in mind, we turn to the circumstances giving rise to

the Mexican Order’s registration in Texas.

Mexican Order

Tucker and Natalia Citlalli Covarrubias Campos (Covarrubias) were married in

2013, and their child was born in 2017 in the United States. After the child’s birth, the child

lived for periods of time in Mexico, where Covarrubias’s family lived, and Travis County, but

the child lived primarily in Mexico in the year preceding the parties’ separation in 2020. In

April 2020, Tucker filed a petition for divorce and suit affecting the parent-child relationship in

Travis County. Among his requested relief, Tucker sought an ex parte temporary restraining

order against Covarrubias. See Tex. R. Civ. P. 680.

On May 15, Covarrubias filed a petition in Mexico concerning custody of their

child, and on May 18, the Mexican Court issued the Mexican Order. The Mexican Order

“concludes that the urgency and need for the requested measure [was] proven”; recites

Covarrubias’s evidence;1 gives Covarrubias “as an interim measure, exclusive provisional

custody of the minor [child]” “with immediate effects”; and requires Tucker “to hand over the

1 The recited evidence in the Mexican Order included that Covarrubias declared under oath that the last time she allowed Tucker to see the child, he did not give the child back to her; Tucker “[had] unjustifiably denied her contact with [the child]”; “he [had] an aggressive and negligent behavior with [the child]”; and “he suffer[ed] from various psychological pathologies that [could] put at risk the life and integrity of [the child].” 3 minor [child] to [Covarrubias].” The order, however, states that its “provisional effects will

inevitably be subject to the results of the main trial” and that it could be modified. It also

required that Tucker be served with its contents and set his deadline to contest the order to be 19

days from the date of service. When the Mexican Order was issued, Tucker was unaware of the

proceeding in Mexico and had not been served. He learned of the Mexican Order on May 22

when his attorney received a copy of it from opposing counsel in the divorce proceeding in

Travis County.

In July, Covarrubias sought to register the Mexican Order in Travis County and

filed certified copies of the order in Spanish and English with the Travis County District Clerk.

See Tex. Fam. Code § 152.305. After Tucker was notified that the Mexican Order had been filed

in Travis County, he timely requested a hearing to contest the validity of the registration, and the

district court held a hearing on his contest in September. Prior to the hearing, the district court

had determined that Mexico was the child’s home state, see id. § 152.201(a)(1) (explaining when

state is home state of child), and at the time of the hearing, Covarrubias had possession of

the child.

At the hearing, Tucker and his attorney testified, and Covarrubias’s witness was

her attorney in the Mexican proceeding. Tucker disputed the factual allegations that are recited

in the Mexican Order and testified that although he became aware of the Mexican proceeding

after the Mexican Order had issued, he had not been officially served and had not participated in

that proceeding. Tucker’s attorney testified that he first learned of the Mexican proceeding in

May after the Mexican Order had issued and that Tucker still had not been served, but the

attorney confirmed that Tucker also had sought an ex parte temporary restraining order among

his requested relief in his petition for divorce and suit affecting the parent-child relationship in

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Eric Leonard Tucker v. Natalia Citalli Covarrubias Campos, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-leonard-tucker-v-natalia-citalli-covarrubias-campos-texapp-2021.