In the Interest of O.L.P., a Child v. the State of Texas

Court of Appeals of Texas·Decided May 21, 2025·No. 04-23-00838-CV·Published

Opinion

Fourth Court of Appeals

San Antonio, Texas

MEMORANDUM OPINION

No. 04-23-00838-CV

IN THE INTEREST OF O.L.P., a Child

From the 285th Judicial District Court, Bexar County, Texas Trial Court No. 2021-CI-14945 Honorable Antonia Arteaga, Judge Presiding

Opinion by: Adrian A. Spears II, Justice

Sitting: Rebeca C. Martinez, Chief Justice Adrian A. Spears II, Justice H. Todd McCray, Justice

Delivered and Filed: May 21, 2025 AFFIRMED In this appeal from a final decree of divorce, Karen Eich challenges the designation of her ex-husband, Evan Porras, as the parent with the exclusive right to designate the primary residence of their child, O.L.P. We affirm.

BACKGROUND

Karen—a German citizen—and Evan—a United States citizen—met while Evan was enlisted in the United States Army and stationed in Germany. They married on December 20, 2018. In April 2019, pursuant to military orders, Evan left Germany and returned to the United States—specifically, San Antonio, Texas—while Karen remained in Germany. In June 2019,

Karen gave birth to O.L.P. When O.L.P. was four months old, Karen and O.L.P. joined Evan in Texas, where the family lived together in an apartment in a community near San Antonio.

By early 2021, Karen and Evan were having marital problems. In March 2021, Karen and O.L.P. traveled to Germany to attend her sister’s wedding and to obtain O.L.P.’s birth certificate. Even though their marriage was unraveling, both Evan and Karen anticipated that Karen and O.L.P. would return to Texas after the trip. However, while Karen was in Germany, Evan told Karen the marriage was over, and Karen decided she and O.L.P. would not return to Texas. Evan initially acquiesced to Karen and O.L.P. remaining in Germany; however, he soon changed his mind and asked Karen to bring O.L.P. back to Texas. Karen refused.

In July 2021, Evan sued Karen for child abduction under the Hague Convention. 1 Evan traveled to Germany for the Hague proceedings. The Hague proceedings were resolved when Evan and Karen reached an agreement for Karen and O.L.P. to return to Texas. Days after Karen and O.L.P. returned to Texas, Evan filed a petition for divorce. Karen answered and counter-petitioned for divorce.

On September 13, 2021, Karen returned to Germany, leaving O.L.P. with Evan in Texas.

On December 29, 2021, Karen and Evan reached an agreement for temporary orders in the divorce proceeding. The trial court approved the agreed temporary orders, which appointed Karen and Evan temporary joint managing conservators of O.L.P. and called for Karen, who was still living in Germany, and Evan, who was still living in Texas, to alternate custody of O.L.P. every three months.

1 The Convention on the Civil Aspects of International Child Abduction, done at The Hague on October 25, 1980, establishes legal rights and procedures for the prompt return of children who have been wrongfully removed or retained. 22 U.S.C. § 9001(a)(4).

1. Trial On November 15 and 16, 2022, the trial court held a two-day bench trial. The main issue was which parent should have the exclusive right to determine O.L.P.’s primary residence. Earlier in the case, the trial court had ordered a child-custody evaluation, which was performed by Dr. Richard R. Theis. Dr. Theis’s written evaluation was admitted into evidence at trial. In his written evaluation, Dr. Theis found that both Karen and Evan were fit to parent O.L.P. and that both parents could provide O.L.P. more than adequate housing, educational opportunities, and extracurricular opportunities; however, he ultimately found that Karen engaged in “more informed parenting,” had “a relatively better ability to meet the child’s emotional needs,” and provided “a very nurturing and supportive environment.” Dr. Theis recommended that the trial court designate Karen the parent with the exclusive right to determine O.L.P.’s residence, which meant that O.L.P.’s primary residence would be in Germany.

a. Evan’s Testimony At trial, Evan testified about the reasons he should be designated the parent with the exclusive right to determine O.L.P.’s residence. Evan had bought a house and “built up a life” for O.L.P. in San Antonio. He said that his plan was to stay in the military, and he would be eligible to retire in ten years. Evan added that he had served in the United States Army for nine years, during which he had been stationed both in the United States and Europe. He was now a surgical technician at Brooke Army Medical Center in San Antonio, Texas. Evan said he did not know if the Army would permit him to return to Germany because in 2021, he had “re-enlisted to stabilize in San Antonio.”

Evan further testified about the pre-school O.L.P. was attending in San Antonio, explaining that it focused on child development. According to Evan, O.L.P. was very smart and she was at

the head of her pre-school class. Evan presented videos and photographs of O.L.P., depicting her life with him in San Antonio. One of the videos showed O.L.P.’s reaction when Evan picked O.L.P. up from pre-school. Another video showed O.L.P.’s reaction when Evan met her at the airport in Germany after she had not seen him for twelve weeks. According to Evan, these videos were especially important because they showed how he and O.L.P. had “a real bond.” The photographs Evan presented showed him and O.L.P. in the backyard of their house in San Antonio. Evan said he had made a swing and a trampoline for O.L.P. and had made sure they were as safe as possible for O.L.P. Evan also presented photographs of O.L.P. in her bedroom, where she loved to play. Evan said that their neighborhood was full of kids, and they had a neighborhood park nearby. Other photographs showed Evan and O.L.P. walking to the park, doing arts and crafts together, spending the day at a lake, attending a wedding, and celebrating Easter. Additionally, Evan testified about the people in Texas who played a role in O.L.P.’s life, such as her godfather and her godfather’s mother, who was “like [a] grandma” to O.L.P.

Evan also testified that while he and Karen were together, he took O.L.P. to all her medical and dental appointments. When O.L.P. returned from Germany, Evan took her to the doctor for a check-up, where O.L.P.’s failure to gain weight raised “red flags.” While she was in Germany with Karen, O.L.P. had dropped on the weight curve from the twenty-fifth percentile to the second percentile. After O.L.P. returned to Texas and lived with Evan for about six weeks, she started gaining weight again, moving up to the sixteenth percentile on the weight curve. Additionally, Evan expressed various concerns about the way Karen cared for O.L.P. while she was in Germany, such as failing to require O.L.P. to wash her hands before eating and failing to dress O.L.P. appropriately for winter weather. Evan also stated that while in Karen’s care in Germany, O.L.P. obtained a large contusion on her forehead. Karen claimed O.L.P. had fallen and hit her head.

Furthermore, Evan testified that while in Germany, Karen ran over a boulder and totaled a car. He believed O.L.P. was in the car when the accident happened.

Evan contended that Dr. Theis overlooked many issues related to Karen’s mental health.

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In the Interest of O.L.P., a Child v. the State of Texas, (Tex. Ct. App. 2025).

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