In the Interest of D.L.C., a Child v. the State of Texas

CourtCourt of Appeals of Texas
DecidedFebruary 27, 2024
Docket01-22-00605-CV
StatusPublished

This text of In the Interest of D.L.C., a Child v. the State of Texas (In the Interest of D.L.C., a Child v. the State of Texas) 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 the Interest of D.L.C., a Child v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

Opinion issued February 27, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-22-00605-CV ——————————— IN THE INTEREST OF D.L.C., A CHILD

On Appeal from the 309th District Court Harris County, Texas Trial Court Case No. 2020-38549

MEMORANDUM OPINION

Appellant, N.M. (Father),1 appeals from the trial court’s final order in this suit

affecting the parent–child relationship. Father argues the trial court erred in

determining the home state of his daughter D.L.C. and in ordering him to pay

1 To protect the identity of the child, we use initials to refer to the child and refer to her parents as “Mother” and “Father.” See TEX. FAM. CODE § 109.002(d). monthly child support and retroactive child support. We modify the trial court’s

order in part, and reverse and remand in part. We affirm the remainder of the order

as modified.

BACKGROUND

D.L.C. was born in August 2019. At the time, her mother and father were not

married to each other, but both lived in Houston. When D.L.C. was about five

months old, in January 2020, she and V.C.F. (Mother) moved to be closer to

Mother’s family in Indiana. They have lived in Indiana ever since. About five

months after D.L.C. and Mother moved, Father filed a petition to adjudicate

parentage in a district court in Harris County, asking the trial court to declare him

D.L.C.’s father. Father continues to live in Houston.

While the suit was pending, Mother and Father entered into a mediated

settlement agreement providing neither party would pay child support at that time,

among other things. The trial court entered a temporary order with the same terms.

Following a bench trial, the trial court entered a final order adjudicating Father

to be D.L.C.’s father and appointing Father and Mother as D.L.C.’s joint managing

conservators. The order stated the trial court’s finding that Indiana is D.L.C.’s

current home state, but Texas was her home state in the six months preceding suit.

The order also required Father to pay $590.87 each month in child support, based on

2 a finding that his monthly net resources were $2,954.33. The order required Father

to pay $15,644.00 in retroactive child support. Father has appealed.

DISCUSSION

Father raises three issues on appeal. First, he argues the trial court erred in

ordering him to pay retroactive child support in spite of the parties’ mediated

settlement agreement not to pay child support while the suit was pending. Second,

he argues the trial court erred in naming both Texas and Indiana as D.L.C.’s home

state. Third, he argues there was no evidence to support the trial court’s finding that

his monthly net resources were $2,954.33, and the trial court erred in basing his

monthly child-support obligations on this amount.

A. Home State

Applicable Law

In child-custody cases involving multiple states, the Uniform Child Custody

Jurisdiction and Enforcement Act (UCCJEA) determines whether a court of a

particular state has jurisdiction to make an initial child-custody determination. See

Powell v. Stover, 165 S.W.3d 322, 325 (Tex. 2005) (orig. proceeding); see also TEX.

FAM. CODE §§ 152.001–.317 (codifying UCCJEA in Texas).2 A Texas court has

2 Whether the word “jurisdiction” in the UCCJEA refers to subject-matter jurisdiction is unclear. The Texas Supreme Court has observed that among courts in other states that have considered the jurisdictional issue, “some refer to the UCCJEA as a subject-matter-jurisdiction statute, while others do not. The issue is not settled.” In re D.S., 602 S.W.3d 504, 517–18 (Tex. 2020) (footnotes omitted). 3 jurisdiction to make an initial child-custody determination if Texas:

is the home state of the child on the date of the commencement of the proceeding, or was the home state of the child within six months before the commencement of the proceeding and the child is absent from this state but a parent or person acting as a parent continues to live in this state[.]

TEX. FAM. CODE § 152.201(a)(1) (emphasis added).

Chapter 152 of the Texas Family Code, this state’s enactment of the UCCJEA,

defines “home state” as “the state in which a child lived with a parent” for “at least

six consecutive months immediately before the commencement of a child custody

proceeding,” or, for a child younger than six months, “the state in which the child

lived from birth with a parent.” TEX. FAM. CODE § 152.102(7).

With some exceptions, the court in the child’s home state that made the initial

child-custody determination “has exclusive continuing jurisdiction over the

determination.” Id. § 152.202(a).

To remedy the problem of courts in different states issuing conflicting child-

custody orders, the UCCJEA prioritizes home-state jurisdiction. Powell, 165 S.W.3d

at 325. Thus, if any state is determined to be the child’s home state, generally no

other state may exercise jurisdiction to make an initial child-custody determination.

See id. By giving prominence to objective factors, like the child’s physical location,

the UCCJEA “helps to avoid the jurisdictional competition and conflict that result

4 when courts in different states determine jurisdiction based on subjective factors.”

Id. at 326.

Construction of the Family Code’s home-state provision is a question of law

we review de novo. Id. at 324.

Analysis

The trial court’s final order stated:

[T]he child currently lives in Indiana[,] and the home state of the child is Indiana; however, the Court finds that it has jurisdiction of this case and of all the parties because . . . Texas was the home state of [t]he child during the last six months prior to the filing of this suit and that no other court has continuing, exclusive jurisdiction of this case.

Father contends the trial court erred by finding Indiana was D.L.C.’s home state in

addition to Texas. Given the UCCJEA’s purpose to avoid conflicting court orders in

multiple states and priority for home-state jurisdiction, see id. at 325, we agree that

after the trial court found Texas was D.L.C.’s home state, the trial court should not

have determined an additional home state.

We conclude that Texas, and only Texas, was D.L.C.’s home state when

Father filed suit. The parties agree that D.L.C. was born on August 22, 2019, and

that on or about January 20, 2020, when she was about five months old, she and her

mother moved to Indiana. Father filed suit about five months after that, on June 29,

2020. Thus, the relevant date for determining D.L.C.’s home state is June 29, 2020.

5 See TEX. FAM. CODE § 152.201(a)(1) (home state determined on date of

commencement of child-custody proceeding).

On that date, D.L.C. had not lived in Indiana for at least six consecutive

months, so Indiana was not her home state. See id. § 152.102(7) (defining “home

state” generally as “the state in which a child lived with a parent” for “at least six

consecutive months immediately before the commencement of a child custody

proceeding”).

The six-month period before Father filed suit spanned from December 29,

2019, to June 29, 2020—the date on which Father filed suit. See id. § 152.201(a)(1)

(jurisdictional inquiry includes whether Texas was child’s home state “within six

months before the commencement of the [child-custody] proceeding”). Within that

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In the Interest of D.L.C., a Child v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-dlc-a-child-v-the-state-of-texas-texapp-2024.