in Re Leticia London

CourtCourt of Appeals of Texas
DecidedMay 17, 2011
Docket14-09-01063-CV
StatusPublished

This text of in Re Leticia London (in Re Leticia London) 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
in Re Leticia London, (Tex. Ct. App. 2011).

Opinion

Reversed and Remanded; Petition for Writ of Mandamus Denied; and Opinion filed May 17, 2011.

In The

Fourteenth Court of Appeals

___________________

NO. 14-09-01045-CV

Leticia London, Appellant

V.

Jeffrey London, Appellee

On Appeal from the 308th District Court

Harris County, Texas

Trial Court Cause No. 1995-51934

NO. 14-09-01063-CV

IN RE Leticia London, Relator

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

308th District Court

OPINION

            A judgment creditor generally cannot foreclose on a homestead to satisfy a debt unrelated to the home, and if a homestead claimant sells the residence, the proceeds are exempt from attachment and execution for six months as a matter of state law.  In this case, Leticia London’s judgment creditor asked the trial court to appoint a receiver and order that if she sold her home, she must turn the sales proceeds over to the receiver.  The trial court granted the creditor’s motion and denied Leticia’s request for disbursement of some of the sales proceeds to her.  Leticia challenged the turnover order through both an appeal and a petition for writ of mandamus; in the latter, she also asked us to compel the trial court to disburse the sales proceeds to her.  We consolidated the two matters, and now hold that the trial court erred in appointing a receiver and in ordering the turnover of Leticia’s homestead-sale proceeds.  We therefore reverse and remand with instructions to the trial court to order the receiver to disburse the sales proceeds to Leticia. 

I.  Factual and Procedural History

            Jeffrey and Leticia divorced in 1995, and Jeffrey was ordered to pay Leticia child support of $1,500 per month for their two children.  In 2001, the trial court increased Jeffrey’s monthly child-support obligation to $4,500 and awarded Leticia her attorney’s fees as child support.  Jeffrey appealed, and we reversed those portions of the trial court’s order.  London v. London, 94 S.W.3d 139, 151 (Tex. App.—Houston [14th Dist.] 2002, no pet.) (“London I”). 

            Leticia immediately filed another motion for modification, and Jeffrey counterclaimed to recoup the $86,250 he paid as increased child support while the earlier appeal was pending.  London v. London, 192 S.W.3d 6, 10 (Tex. App.—Houston [14th Dist.] 2005, pet. denied) (“London II”).  The trial court ruled in Leticia’s favor, increased Jeffrey’s monthly support obligation from $1,500 to $3,000, and awarded Leticia $6,000 in retroactive child support.  The trial court also denied Jeffrey’s recoupment claim and awarded Leticia $12,000 for attorney’s fees in the nature of child support.  Id.  Jeffrey appealed, and again we reversed.  Id. at 19–20.  We rendered judgment against Leticia for the increased child support Jeffrey paid while his two successful appeals were pending. 

            Jeffrey still had not been paid when he learned in 2009 that Leticia was attempting to sell her homestead and had specified that the title company pay part of the proceeds to the creditors she identified in the closing statement.  Before the closing, Jeffrey asked the trial court to appoint a receiver and order Leticia to deliver the proceeds from any sale to the receiver.  On December 1, 2009, the trial court signed an “Order Granting Turnover and Appointing Receiver.”  In the order, the trial court appointed and authorized a receiver to seize Leticia’s non-exempt assets and pay the proceeds to Jeffrey to the extent necessary to satisfy the judgment.  The same day, however, the trial court also signed an order entitled, “Final Judgment on Application for Turnover and Appointment of a Receiver Pursuant to Chapter 31 of the Texas Civil Practice and Remedies Code.”  In this order, the trial court again appointed the same receiver and ordered that if Leticia sold her homestead, she was to turn over the sales proceeds to the receiver. 

            While expressly reserving her right to appeal, Leticia moved for the disbursement of proceeds to pay some of her creditors.  The trial court denied most of the requested relief, but ordered that if Leticia presented bills to the receiver to substantiate her debts, then the receiver could pay $1,874.00 to Leticia’s landlord for past-due rent and late fees, $245.99 to her electricity provider for her overdue electric bill, and $109.46 to another utility company for her outstanding water bill.  The trial court refused to order the receiver to pay $4,877.71 to the Internal Revenue Service for Leticia’s back taxes; $1,056.48 to the bank financing her automobile loan for past-due payments, and $5,000.00 to her attorney for legal fees.  

            In partial compliance with the trial court’s order, Leticia delivered a portion of the proceeds to the receiver.[1]  She appealed the trial court’s order appointing the receiver and requiring her to deliver to the receiver the proceeds from the sale of her homestead, and filed a petition for a writ of mandamus asking us to compel the trial court to order the receiver to disburse the sale proceeds directly to her.  We consolidated the two matters. 

II.  Standard of Review

            We begin our review with Leticia’s appeal of the order appointing a receiver and requiring her to deliver the proceeds from the sale of her home to him.  As we have previously stated, “receivership is a drastic remedy, to be used sparingly in the context of private litigation.”  Covington Knox, Inc. v. State, 577 S.W.2d 323, 326 (Tex. Civ. App.—Houston [14th Dist.] 1979, no writ).  It nevertheless is a matter committed to the trial court’s discretion, and we will not disturb that decision absent a clear abuse of discretion.  Id. at 325.  We similarly review turnover orders for abuse of discretion.  Barrera v. State, 130 S.W.3d 253, 261 (Tex. App.—Houston [14th Dist.] 2004, no pet.) (citing Beaumont Bank, N.A. v. Buller, 806 S.W.2d 223, 226 (Tex. 1991)).

III.  Analysis

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Bluebook (online)
in Re Leticia London, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-leticia-london-texapp-2011.