in Re: R. Jeanette Hammond

CourtCourt of Appeals of Texas
DecidedJanuary 15, 2004
Docket08-03-00400-CV
StatusPublished

This text of in Re: R. Jeanette Hammond (in Re: R. Jeanette Hammond) 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: R. Jeanette Hammond, (Tex. Ct. App. 2004).

Opinion

COURT OF APPEALS

COURT OF APPEALS

EIGHTH DISTRICT OF TEXAS

EL PASO, TEXAS

IN RE:  R. JEANETTE HAMMOND,

                            Relator.

'

No. 08-03-00400-CV

AN ORIGINAL PROCEEDING

IN HABEAS CORPUS

O P I N I O N

R. Jeanette Hammond filed a petition for writ of habeas corpus in this Court, seeking to be discharged from confinement pursuant to a trial court order holding her in contempt for failing to pay child support.  On August 29, 2003, this Court granted the writ and ordered her discharged upon the posting of a $100 bond.  For the reasons that follow, we overrule the issues raised by Hammond in this proceeding.  Therefore, we will remand her to the custody of the El Paso County Sheriff.

Factual and Procedural Background


Hammond and Wiley F. James, III, are the parents of a daughter.  On June 1, 2001, they agreed to an order that requires Hammond to pay James $443.57 per month in child support.  The order further provides that if James determines that their daughter=s best interest would be served by attending private school or by receiving tutoring, he is authorized to enroll her in a private school of his choice or to make arrangements for tutoring, and Hammond must pay 50 percent of the costs.  Hammond must also pay 50 percent of their daughter=s uninsured medical expenses.

James later filed a motion in the 171st Judicial District Court to enforce the order and to hold Hammond in contempt.  He alleged that Hammond had violated the order by failing to pay child support or to reimburse him for uninsured medical expenses and private school tuition.  James requested that Hammond be held in civil contempt for disobeying the order.

On August 14 and 15, 2003, the parties appeared along with counsel for a hearing on James=s motion.  On August 15, the trial court signed an order holding Hammond in criminal and civil contempt.  The court determined that Hammond was in arrears on her child support obligation in the amount of $5,866.19, was in arrears on her obligation for private school tuition in the amount of $6,623.68, and was in arrears on her obligation to pay uninsured medical expenses in the amount of $1,284.75.  The total arrearage was $13,774.62.


Hammond failed to make fifteen child support payments, two payments for private school expenses, and seventy-two payments for uninsured medical expenses.  In assessing punishment for criminal contempt, the court sentenced her to sixty days in jail for each of these eighty-nine violations, to be served consecutively.  In sanctioning Hammond for civil contempt, the court ordered Hammond to be confined until she pays the total arrearage of $13,774.62 and James=s attorneys= fees in the amount of $17,000.28.  But the court suspended her commitment until August 28 and provided that if she paid the total arrearage and the attorneys= fees by that date, she would not go to jail.

Because Hammond failed to pay the amount due by August 28, she was committed to jail on that date.  On August 29, she filed a petition for writ of habeas corpus and was released from jail by order of this Court, upon the posting of a $100 bond.

The case was subsequently transferred from the 171st Judicial District Court to the 383rd Judicial District Court.  On November 8, 2003, the 383rd Judicial District Court signed a nunc pro tunc order.  This order is substantially similar to the August 28 order, except that it does not contain a finding of criminal contempt.

Hammond=s Arguments

Hammond argues that she was denied her right to a jury trial and that she was denied due process because she does not have the ability to pay the amounts ordered by the trial court, she was not allowed an opportunity to present evidence of her inability to pay, and the trial court failed to make a finding that she had the ability to pay.  She also argues generally that her confinement is illegal, unconstitutional, excessive, cruel, and unusual, and an abuse of discretion.


Standard of Review

In a habeas corpus proceeding, the guilt or innocence of the relator is not an issue.  Ex parte Kimsey, 915 S.W.2d 523, 525 (Tex. App.--El Paso 1995, orig. proceeding).  The only issue is the legality of the relator=s confinement.  Id.  A writ of habeas corpus will not issue if a contempt order is merely erroneous.  Ex parte Swate, 922 S.W.2d 122, 124 (Tex. 1996).  But a writ will issue if the order is void.  Id.; Kimsey, 915 S.W.2d at 525.  In the context of a habeas proceeding, a contempt order is void if it is beyond the power of the court to enter or if it deprives the relator of liberty without due process of law. 

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