M.G. v. T.G.

CourtCourt of Appeals of Texas
DecidedFebruary 23, 2023
Docket02-21-00433-CV
StatusPublished

This text of M.G. v. T.G. (M.G. v. T.G.) 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
M.G. v. T.G., (Tex. Ct. App. 2023).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-21-00433-CV ___________________________

M.G., Appellant

V.

T.G., Appellee

On Appeal from the 467th District Court Denton County, Texas Trial Court No. 20-2472-462

Before Kerr, Wallach, and Walker, JJ. Memorandum Opinion by Justice Kerr MEMORANDUM OPINION

In this restricted appeal, we consider whether sufficient evidence supports the

property division, child support, and attorney’s fees ordered in a default divorce and

SAPCR.1 Because the evidence does not support the property division and the total

child-support and attorney’s-fees awards, we reverse the judgment in part and remand

the case for a limited new trial.

Background

Appellant M.G. and Appellee T.G. married in 2016 and then had two children.

The couple separated in 2020. In March 2020, M.G. filed for divorce. In both March

and November 2020, she absconded with both children, who were found by law

enforcement. T.G. filed a counterpetition for divorce.

M.G. answered some discovery, but the parties did not exchange or file sworn

inventories of their property.2 After responding to T.G.’s discovery requests, M.G.’s

counsel moved to withdraw from representation because she had “not been able to

effectively communicate with” M.G. The trial court allowed M.G.’s counsel to

withdraw in mid April 2021, a little over a month and a half before the June 7,

2021 trial setting. M.G. took no further action in the trial court.

A SAPCR is a suit affecting the parent–child relationship. See Tex. Fam. Code 1

Ann. § 101.032(a). 2 M.G.’s counsel said in her forwarding email that M.G. “basically has no financial information” and that counsel understood T.G. “made all of the financial payments for obligations while they were living together.”

2 Although T.G. appeared for the trial, M.G. did not. T.G. testified about the

circumstances leading to the divorce, including M.G.’s mental-health and substance-

abuse problems––both before and after they sought a divorce––as well as M.G.’s

arrests and Child Protective Services involvement3 during the divorce’s pendency.

T.G. also testified that their 2016 car that M.G. had been driving since October

2021 was impounded in March 2021 and he had to pick it up. The car appeared to

have been crashed on multiple occasions; had writing on the console and a cigarette

burn inside; was full of food, garbage, clothing, and other items; and reeked of

cigarettes. According to T.G., the car was totaled.

T.G. testified that he and the children were living in a home that he and M.G.

had bought after marrying; its 2020 appraised value was “about $281,000,” and he

estimated their equity in the home to be $193,000. T.G. expected to continue making

the mortgage payments and wanted to remain living there with the children. 4

T.G. testified that he was seeking $130 a month for the children’s health

insurance, child support from January 2021 through June 2021, and prospective child

3 CPS, a Texas Department of Family and Protective Services division, became involved with M.G. and the children in March 2020 after M.G. filed for divorce and alleged that T.G. had sexually abused their daughter. CPS ruled out the allegations. 4 Before her counsel withdrew, M.G. had filed an amended petition in which she sought to have the home sold and the proceeds divided. She also asked the trial court to confirm as her separate property “all property [she] owned and claimed . . . before her marriage” and asserted a claim for reimbursement to her separate estate for community-estate contributions.

3 support based on what he estimated M.G.’s earning capacity to be based on her

education and work experience: $15 per hour. 5 T.G. also testified that M.G. was the

beneficiary of a trust fund created before their marriage and that he had no access to

or control over that fund.

The trial court admitted a summary of T.G.’s proposed relief, in which he

sought to have the following property awarded to him:

• the marital residence “with all equity, furniture, furnishings, fixtures and items located” there and all associated debt and tax obligations;

• a 2008 truck and the totaled 2016 car;

• “[a]ll financial accounts, retirement accounts, and other assets in his possession or subject to his control”;

• “[h]is personal belongings, including computers, clothes, and jewelry”; and

• “all credit card debt or loans in his name.”

T.G. also asked the trial court to award M.G.

• “[a]ll financial accounts, retirement accounts, and other assets in her possession or subject to her control”;

• “[h]er personal belongings, including computers, clothes, and jewelry”;

• “all credit card debt or loans in her name”; and

• “[a]ny outstanding medical bills, psychiatric bills, criminal fees or fines, in her name.”

5 He estimated that at $15 per hour, her child-support obligation would be $500 per month.

4 Finally, T.G. sought an order for M.G. to pay his attorney $25,000 for fees through

trial and $469 for expenses.6

The trial court rendered its ruling on the record. It granted the divorce and

T.G.’s requested property division, child support, $130 monthly medical-insurance

reimbursement, and attorney’s fees. The trial court also named T.G. the children’s

sole managing conservator with the exclusive right to determine their residence.7

On July 1, 2021, the trial court signed the final judgment incorporating its trial

rulings. M.G. filed this restricted appeal a little over five months later.

Issues and Standards of Review

In a single issue with five subissues, M.G. challenges the evidentiary sufficiency

of the prospective and retroactive child-support awards, the property division, and the

attorney’s-fees award.8 We apply the same standard of review––abuse of discretion––

to her child-support and property-division challenges. See Sandone v. Miller-Sandone,

Both T.G. and his counsel testified about the amount of attorney’s fees and 6

expenses he had incurred. The expenses were for records-subpoena and witness fees.

M.G. has not challenged the part of the judgment granting a divorce, nor has 7

she challenged any of the judgment’s non-child-support SAPCR provisions–– conservatorship and possession and access. 8 M.G. argues in her first subissue that she has met the requirements for a restricted appeal. T.G. agrees that M.G. has met the jurisdictional requirements for bringing a restricted appeal but does not concede error apparent on the face of the record. See Tex. R. App. P. 26.1(c), 30; In re S.W., 614 S.W.3d 311, 313 (Tex. App.–– Fort Worth 2020, no pet.). Therefore, we will review her remaining subissues about error. See Norman Commc’ns v. Tex. Eastman Co., 955 S.W.2d 269, 270 (Tex. 1997) (holding that restricted-appeal error review includes sufficiency review).

5 116 S.W.3d 204, 205 (Tex. App.—El Paso 2003, no pet.) (“Most of the appealable

issues in a family[-]law case are evaluated against an abuse of discretion standard, be it

the issue of property division incident to divorce or partition, conservatorship,

visitation, or child support.”).

A trial court abuses its discretion if it acts arbitrarily or unreasonably or if it

does not analyze or apply the law properly. Iliff v.

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