In the Matter of the Marriage of Mary Caroline Guggenheim and Erik Wade Guggenheim v. the State of Texas

CourtCourt of Appeals of Texas
DecidedOctober 15, 2024
Docket06-24-00033-CV
StatusPublished

This text of In the Matter of the Marriage of Mary Caroline Guggenheim and Erik Wade Guggenheim v. the State of Texas (In the Matter of the Marriage of Mary Caroline Guggenheim and Erik Wade Guggenheim 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.

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In the Matter of the Marriage of Mary Caroline Guggenheim and Erik Wade Guggenheim v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In the Court of Appeals Sixth Appellate District of Texas at Texarkana

No. 06-24-00033-CV

IN THE MATTER OF THE MARRIAGE OF MARY CAROLINE GUGGENHEIM AND ERIK WADE GUGGENHEIM

On Appeal from the 43rd District Court Parker County, Texas Trial Court No. CV23-0983

Before Stevens, C.J., van Cleef and Rambin, JJ. Memorandum Opinion by Chief Justice Stevens MEMORANDUM OPINION

Erik Wade Guggenheim appeals from a final decree divorcing him from Mary Caroline

Guggenheim. On appeal, Erik argues that the trial court erred by entering judgment in

accordance with a marital settlement agreement (MSA) because (1) the judgment was entered

without notice and a hearing and (2) he revoked his agreement to the settlement.1 Because we

find that Erik was entitled to notice and a hearing, we reverse the trial court’s judgment.

I. Factual and Procedural Background

Erik and Mary had been married since March 6, 2021. The two stopped living together

on January 17, 2023. There were no children of the marriage and, on January 28, Erik and Mary

entered into an MSA.

In June 2023, Mary filed a petition for divorce from Erik, attached the MSA, and asked

the trial court to divide the marital estate in accordance with its terms. The MSA was signed by

both Mary and Erik, and their signatures were acknowledged by a notary public. Mary and Erik

also initialed each page of the MSA. Pursuant to the terms of the MSA, the parties agreed to

divide their community property and liabilities, including real and personal property, business

interests, and debts. The MSA noted that it was binding, and both Erik and Mary acknowledged

that they understood the provisions of the MSA and agreed to it voluntarily.

In response to Mary’s petition, Erik filed a counter-petition for divorce. In his counter-

petition, Erik accused Mary of adultery and sought a just and right division of the marital estate.

When Mary moved for the trial court to sign a decree of divorce based on the MSA, Erik filed a 1 Originally appealed to the Second Court of Appeals, this case was transferred to this Court by the Texas Supreme Court pursuant to its docket equalization efforts. See TEX. GOV’T CODE ANN. § 73.001 (Supp.). We follow the precedent of the Second Court of Appeals in deciding the issues presented. See TEX. R. APP. P. 41.3. 2 document purporting to repudiate his agreement to it. In writing, Erik agreed that he was a party

to the MSA and had signed it but argued that it was not binding under the Texas Family Code.

He then moved the trial court to set aside the MSA. This prompted Mary to amend her petition

to include a claim for anticipatory breach of the MSA.

Mary filed a brief with the trial court in support of upholding the MSA, while Erik

submitted briefing in support of his request to set aside the MSA. On March 4, 2024, the trial

court entered an order upholding the MSA. On March 13, 2024, Mary filed a proposed final

decree of divorce along with a letter asking the trial court to sign it if no objection was received

within ten days thereof. No objection was brought by Erik. As a result, on March 26, without

notice or a hearing, the trial court entered the decree of divorce dividing the community assets in

accordance with the MSA.

I. Due Process Required Notice and a Hearing

In his first point of error on appeal, Erik argues that the trial court erred in rendering

judgment in this contested case without notice and a hearing, which violated his right to due

process. We agree.

Under Rule 245 of the Texas Rules of Civil Procedure, “[t]he Court may set contested

cases . . . with reasonable notice of not less than forty-five days to the parties of a first setting for

trial, or by agreement of the parties.” Highsmith v. Highsmith, 587 S.W.3d 771, 777 (Tex. 2019)

(per curiam) (quoting TEX. R. CIV. P. 245). Only “[n]oncontested cases may be tried or disposed

of at any time whether set or not.” Id. (quoting TEX. R. CIV. P. 245). When, as in this case, “a

party files an answer, he makes an appearance and places in issue the matters raised in the

3 plaintiff’s petition, and the case becomes contested.” M.B. v. R.B., No. 02-19-00342-CV, 2021

WL 2252792, at *4 (Tex. App.—Fort Worth June 3, 2021, no pet.) (mem. op.) (citing Highsmith,

587 S.W.3d at 777). As a result, “due process rights are violated when a judgment is

subsequently entered without the party having received notice of the setting of the case.” In re

K.M.L., 443 S.W.3d 101, 119 (Tex. 2014).

In response to Erik’s appellate argument, Mary does not argue that there was proper

notice and a hearing. Instead, Mary argues that Erik failed to preserve this issue for appeal. But

“[d]ue process demands that a party be afforded ‘an opportunity to be heard at a meaningful time

and in a meaningful manner.’” Highsmith, 587 S.W.3d at 778 (quoting Univ. of Tex. Med. Sch.

at Houston v. Than, 901 S.W.2d 926, 930 (Tex. 1995)). For this reason, the Texas Supreme

Court has written that “a lack of notice violates basic principles of due process.” Id. (citing

Peralta v. Heights Med. Ctr., Inc., 485 U.S. 80, 84 (1988) (explaining that a “[f]ailure to give

notice violates ‘the most rudimentary demands of due process of law’”)); see Campsey v.

Campsey, 111 S.W.3d 767, 771 (Tex. App.—Fort Worth 2003, no pet.) (“A trial court’s failure

to comply with the rules of notice in a contested case deprives a party of the constitutional right

to be present at the hearing and to voice his objections in an appropriate manner, and results in a

violation of fundamental due process.”). While it is true that “[t]he due process right to notice

prior to judgment is subject to waiver,” “such waiver must be voluntary, knowing, and

intelligently waived.” In re K.M.L., 443 S.W.3d at 119.

With this in mind, we turn to Mary’s argument that Erik waived his due process argument

by failing to object to her proposed final decree of divorce. The record shows that Mary filed the

4 proposed decree along with a letter asking the trial court to sign it if no objection was received

within ten days thereof. Even so, the letter did not absolve the trial court of its requirement to

provide notice comporting with due process or its requirement under Rule 245 to give Erik no

less than forty-five days’ notice. Moreover, Mary has cited no case supporting the proposition

that failing to object to an opposing party’s letter providing only ten days’ notice results in a

knowing, intelligent, or voluntary waiver of his right to fundamental due process or to notice

under Rule 245, and we have found none.

Next, Mary notes that the proposed final decree, which her counsel drafted and the trial

court signed, contained a notation that both Mary and Erik failed to appear. Mary argues that

that creates a presumption in her favor since a “trial court presumably will hear a case only when

notice has been given to the parties.” Campsey, 111 S.W.3d at 771. “To overcome this

presumption, an appellant must affirmatively show lack of notice.” Id. Here, Erik has overcome

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Related

Peralta v. Heights Medical Center, Inc.
485 U.S. 80 (Supreme Court, 1988)
Custom-Crete, Inc. v. K-Bar Services, Inc.
82 S.W.3d 655 (Court of Appeals of Texas, 2002)
Campsey v. Campsey
111 S.W.3d 767 (Court of Appeals of Texas, 2003)
Padilla v. Commission for Lawyer Discipline
87 S.W.3d 624 (Court of Appeals of Texas, 2002)
University of Texas Medical School at Houston v. Than
901 S.W.2d 926 (Texas Supreme Court, 1995)
in the Interest of K.M.L., a Child
443 S.W.3d 101 (Texas Supreme Court, 2014)
In the Interest of A.D.A. and S.L.A., Children
287 S.W.3d 382 (Court of Appeals of Texas, 2009)
Williams Farms Produce Sales, Inc. v. R & G Produce Company
443 S.W.3d 250 (Court of Appeals of Texas, 2014)
in the Matter of the Marriage of Herman Tyeskie and Inger Tyeskie
558 S.W.3d 719 (Court of Appeals of Texas, 2018)

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