In the Matter of the Marriage of Jeffrey Wayne Maynard and Tiffini Sweet Maynard v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJune 26, 2024
Docket07-23-00202-CV
StatusPublished

This text of In the Matter of the Marriage of Jeffrey Wayne Maynard and Tiffini Sweet Maynard v. the State of Texas (In the Matter of the Marriage of Jeffrey Wayne Maynard and Tiffini Sweet Maynard 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 Matter of the Marriage of Jeffrey Wayne Maynard and Tiffini Sweet Maynard v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-23-00202-CV

IN THE MATTER OF THE MARRIAGE OF JEFFREY WAYNE MAYNARD AND TIFFINI SWEET MAYNARD

On Appeal from the 47th District Court Randall County, Texas Trial Court No. 79774-A, Honorable Dan L. Schaap, Presiding

June 26, 2024 MEMORANDUM OPINION Before QUINN, C.J., and PARKER and DOSS, JJ.

This appeal from a final decree of divorce dividing marital property tests the

distinction between one’s personal goodwill and commercial goodwill. Personal goodwill,

which includes the value of one’s confidence in a professional’s skills and abilities, for

example, is not a property right that is subject to division on divorce.1 Commercial

goodwill, which is subject to division upon divorce, “exists separate and apart from a

professional’s personal skills, ability, and reputation.”2 Appellant, Tiffini Sweet Maynard

1 Nail v. Nail, 486 S.W.2d 761, 764 (Tex. 1972).

2 Keith v. Keith, 763 S.W.2d 950, 952 (Tex. App.—Fort Worth 1989, no pet.). (Wife), presents three issues challenging the trial court’s division of the community estate.

Appellee is Jeffrey Wayne Maynard (Husband). For the reasons set forth below, we

overrule Wife’s issues and affirm the judgment of the trial court.

Background

Husband and Wife married in 1998 and ceased living as spouses in 2021.

Husband began a career as a financial advisor in the early 2000s. On December 15,

2014, Husband and MKD Financial Services, LP, entered into an agreement

memorialized in a document titled “Non-Compete Representative Agreement.” According

to the agreement, Husband, as MKD’s independent contractor, would “solicit[] purchases

of securities.” Husband’s compensation for services rendered under the agreement was

stated to be commission-based. For business written by Husband after June 1, 2014, he

would receive “35% on 401(k) and Individual Client net revenue.”

For business written before April 1, 2014, Husband would receive “52% on 401(k)

and Individual Client net revenue generated by [Husband’s] efforts.” An “override

agreement” for business written before April 2014, allowed Husband to increase his

compensation percentage from 52% to 64% if “net GDC” exceeded $700,001. A

paragraph entitled “Client Relationship,” the agreement stipulated that “[o]nly those clients

listed and agreed upon on Exhibit B . . . are deemed clients of [Husband] and with whom

[Husband] shall be entitled to continue business following termination of this agreement.”

It is undisputed that Exhibit B was never generated.

The trial court rendered a divorce on January 4, 2023, and signed the decree on

February 28, 2023. On Wife’s request, the court made numerous findings of fact and

2 conclusions of law, which included the following regarding the non-compete agreement

between Husband and MKD:

[T]he right to receive a greater share of revenue in the future for business written prior to 4/1/2014 in paragraph 2 of the 2014 Non-Compete Representative Agreement is not a marital asset for which division is appropriate. There was no commercial goodwill transferred to MKD by virtue of [Husband’s] personal employment with the company or by virtue of the Agreement. The right to receive a greater share of revenue for business written prior to 4/1/2014 in paragraph 2 of the 2014 Non-Compete Representative Agreement is income earned for services and is Husband’s future separate property.

This appeal followed.

Analysis

Through three issues, Wife argues the trial court abused its discretion 3 in dividing

the marital estate because it failed to make a just and right division of property regarding

the agreement’s sale of commercial goodwill. The Texas Family Code requires a “just

and right” division of the community estate when spouses divorce. TEX. FAM. CODE ANN.

3 The Fort Worth Court of Appeals recently discussed the applicable standard of review for family

law community division questions:

In family-law cases, the traditional sufficiency standards of review overlap with the abuse- of-discretion standard of review; therefore, legal and factual insufficiency are not independent grounds of error but are relevant factors in our assessment of whether the trial court abused its discretion. To determine whether there has been an abuse of discretion because the evidence is legally or factually insufficient to support the trial court’s decision, we must determine (1) whether the trial court had sufficient evidence upon which to exercise its discretion and (2) whether the trial court erred in its application of that discretion. The applicable sufficiency review comes into play with regard to the first question.

Rice v. Rice, No. 02-21-00413-CV, 2023 Tex. App. LEXIS 39, at *23 (Tex. App.—Fort Worth 2023, no pet.) (mem. op.) (internal citations omitted).

3 § 7.001. As noted above, there is a distinction between personal goodwill (which is not a

part of community property) and commercial goodwill (which may be). Relevant here, we

examine whether goodwill exists independent of the personal ability of the professional

spouse, and if so, whether that goodwill has a commercial value attributable to the marital

estate. Hill v. Hill, No. 02-12-00332-CV, 2014 Tex. App. LEXIS 292, at *15 (Tex. App.—

Fort Worth Jan. 9, 2014, no pet.) (mem. op.). Determining the existence of goodwill and

its value are fact questions for the trier of fact, which in this case is the trial court. Hill,

2014 Tex. App. LEXIS 292, at *23.

The trial court was asked to answer this question: is any part of the compensation

paid to Husband for business written before April 1, 2014, properly attributed as

commercial goodwill? Wife argues, “The Agreement [] unambiguously calls for the

conveyance of Husband’s commercial goodwill to MKD.” Wife contends the non-compete

agreement’s two-tier compensation arrangement – which pays “almost twice as large a

share of revenue” for “Legacy” (i.e., pre-April 2014) clients – constitutes proof that such

compensation serves as consideration for obtaining Husband’s clients (commercial

goodwill).

Wife supports her position with the expert testimony of Owen Dahl. Dahl compared

the percentage to be paid to Husband for Legacy versus new clients and found that pre-

2014 clients carry a 32-point premium. He attributes this portion to a sale of Husband’s

client book to MKD, adding that the percentage is “the industry norm” for a sale of clients.

However, as to why Husband would receive the same percentage for a sale of clients as

obtaining and maintaining clients, Dahl equivocated, testifying, “[A]s I said, I don’t know if

that’s coincidental or purposeful, but it’s interesting for sure.”

4 Husband denied bringing a list of clients to MKD and responded “I don’t know”

when asked about receiving proceeds from any sale. He testified that the purpose for the

agreement’s payment terms was “[t]o get a revenue split more in line with a typical

advisor.”4 Husband initially explained the differential between payment for “Legacy” and

“new” clients as “[j]ust the agreement we came up with.” However, he later added that

because the agreement paid roughly 65% for pre-April 2014 clients and “flopped” to

approximately 35% for new clients, he and MKD are reaching an intended overall revenue

formula “closer to 50/50.”

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Related

Nail v. Nail
486 S.W.2d 761 (Texas Supreme Court, 1972)
Keith v. Keith
763 S.W.2d 950 (Court of Appeals of Texas, 1989)

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