Jane E. Dunham v. David M. Dunham

CourtCourt of Appeals of Texas
DecidedJuly 26, 1995
Docket10-94-00272-CV
StatusPublished

This text of Jane E. Dunham v. David M. Dunham (Jane E. Dunham v. David M. Dunham) 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
Jane E. Dunham v. David M. Dunham, (Tex. Ct. App. 1995).

Opinion

Dunham v. Dunham


IN THE

TENTH COURT OF APPEALS


No. 10-94-272-CV


        JANE E. DUNHAM,

                                                                                               Appellant

        v.


        DAVID M. DUNHAM,


                                                                                               Appellee


From the 249th District Court

Johnson County, Texas

Trial Court # 5063-93


O P I N I O N


          Jane Dunham appeals the property division in a divorce decree. The court, granting the divorce on the grounds of insupportability, denied Jane's claim of constructive fraud, divided the community property, and awarded her a $15,000 judgment against her husband, David Dunham. Jane brings five points of error.

          The first three points relate to her claim of constructive fraud. Jane generally claims that a number of David's expenditures during their marriage created a presumption of constructive fraud. In point one Jane complains that the court did not require David to overcome the presumption of constructive fraud and demonstrate that the expenditures were fair to her. In points two and three, she alleges that there was no evidence, or insufficient evidence, that the transactions were fair to her.

          The fourth point asserts that the court erred in failing to reimburse the community estate for payments David made on his separate-property debts and to his sons and mother. Her fifth point alleges that the court erred in failing to award her at least 50% of the community estate.

BACKGROUND

          Jane, a teacher, and David, an orthodontist, married on August 12, 1988, and divorced on May 9, 1994. At the time of the marriage, David was the sole owner of his orthodontist practice in Cleburne. He brought a substantial amount of separate property into the marriage, and he continued to make payments on various premarital debts during the marriage. Issues relating to David's separate property and payment of the premarital debts are the primary source of Jane's complaints.

          David paid on two notes that existed prior to his marriage to Jane and were payable to Irene Dunham (David's ex-wife). One note was a court-ordered, unsecured note executed incident to his divorce from Irene. David paid a total of $33,800 on that note during his marriage to Jane. The second note payable to Irene was for David's purchase of real property that he used for his orthodontist practice. The principal amount of the second note decreased during the marriage by $89,526, thereby increasing David's equity interest in the property by that amount. The court also found that David paid another $140,188 in expenses on the property during his marriage to Jane.

          Jane also complains of monies David spent on a number of automobiles during their marriage. Two were Hondas (1985 and 1987 models), which were the subject of one premarital promissory note (the "Honda" note). David allowed his mother and one of his sons to drive these cars. David bought a third car, a 1988 Honda, during the marriage and renewed the prior Honda note to include the new car. Finally, Jane complains of one or more gifts to another of David's sons for the purchase of two cars during their marriage.

CONSTRUCTIVE FRAUD

          Jane claims that the above expenditures, which were made by David from community funds during the marriage, were unfair to her, thus giving rise to a claim for constructive fraud. Constructive fraud is the breach of a legal or equitable duty, which the law declares fraudulent because it violates a fiduciary relationship. Fanning v. Fanning, 828 S.W.2d 135, 148 (Tex. App.—Waco 1992), rev'd on other grounds, 847 S.W.2d 225 (Tex. 1993). A presumption of constructive fraud arises when a spouse unfairly disposes of the other spouse's interest in community property without the other's knowledge or consent, and the disposing spouse has the burden to prove the fairness of the disposition. Matter of Marriage of Devine, 869 S.W.2d 415, 422 (Tex. App.—Amarillo 1993, writ denied) (citing Mazique v. Mazique, 742 S.W.2d 805, 808 (Tex. App.—Houston [1st Dist.] 1987, no writ)) (emphasis added). Only gifts that are excessive and capricious, made with intent to defraud the other spouse, may be set aside as a constructive fraud. Fanning, 828 S.W.2d at 148.

          Jane cites four occurrences in support of her argument of constructive fraud: (1) the payments relating to David's business property; (2) payments on David's unsecured debt to his ex-wife; (3) payments on the Honda note; and (4) the expenditure of approximately $8,000 on used automobiles for David's middle son.

          There is no evidence that any of the complained-of actions were taken without Jane's knowledge and consent. See Marriage of DeVine, 869 S.W.2d at 422; Tabassi v. NBC Bank—San Antonio, 737 S.W.2d 612, 617 (Tex. App.—Austin 1987, writ ref'd n.r.e.). In fact, Jane's own testimony establishes the contrary. She testified that she was aware of the payments to Irene Dunham, and of the payments on the two Hondas used by David's mother and son. She testified that she was "just more than glad whatever [David] did for [his kids], to put them through school, to pay for their cars." Further, Jane testified that she helped David's son pick out one car, the purchase of which she now claims is fraudulent. Jane knew that David was spending money on cars for his sons, and, from her testimony, she not only consented but approved. Further, we recognize that a portion of the Honda note is for the purchase of David's 1988 Honda that was made during the marriage. It is, therefore, community property and would properly be paid for with community assets. See Tex. Fam. Code Ann. § 5.01(b) (Vernon 1993).

           These facts do not give rise to a presumption of constructive fraud. The evidence established that Jane knew of, approved of, or consented to each of the transactions of which she now complains, and there is no evidence that the transactions were otherwise unfair to her. See Fanning, 828 S.W.2d at 148; Marriage of DeVine, 869 S.W.2d at 422; and Tabassi, 737 S.W.2d at 617.

          Jane also complains that, once the parties were separated, David paid approximately $16,000 to discharge the Honda note rather than applying that money to the community tax debt that, as of January 1, 1993, totalled $59,000.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

LeBlanc v. LeBlanc
761 S.W.2d 450 (Court of Appeals of Texas, 1988)
Mazique v. Mazique
742 S.W.2d 805 (Court of Appeals of Texas, 1987)
Holt Atherton Industries, Inc. v. Heine
835 S.W.2d 80 (Texas Supreme Court, 1992)
Fanning v. Fanning
828 S.W.2d 135 (Court of Appeals of Texas, 1992)
Penick v. Penick
783 S.W.2d 194 (Texas Supreme Court, 1990)
Fanning v. Fanning
847 S.W.2d 225 (Texas Supreme Court, 1993)
Tabassi v. NBC Bank-San Antonio
737 S.W.2d 612 (Court of Appeals of Texas, 1987)
Holley v. Holley
864 S.W.2d 703 (Court of Appeals of Texas, 1993)
Downer v. Aquamarine Operators, Inc.
701 S.W.2d 238 (Texas Supreme Court, 1985)
Matter of Marriage of DeVine
869 S.W.2d 415 (Court of Appeals of Texas, 1994)
Murff v. Murff
615 S.W.2d 696 (Texas Supreme Court, 1981)
Vallone v. Vallone
644 S.W.2d 455 (Texas Supreme Court, 1982)

Cite This Page — Counsel Stack

Bluebook (online)
Jane E. Dunham v. David M. Dunham, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jane-e-dunham-v-david-m-dunham-texapp-1995.