Monica Vasquez Parsons v. Paul G. Parsons

CourtCourt of Appeals of Texas
DecidedOctober 22, 2019
Docket01-18-00902-CV
StatusPublished

This text of Monica Vasquez Parsons v. Paul G. Parsons (Monica Vasquez Parsons v. Paul G. Parsons) 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
Monica Vasquez Parsons v. Paul G. Parsons, (Tex. Ct. App. 2019).

Opinion

Opinion issued October 22, 2019

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-18-00902-CV ——————————— MONICA VASQUEZ PARSONS, Appellant V. PAUL G. PARSONS, Appellee

On Appeal from the 310th District Court Harris County, Texas Trial Court Case No. 2017-77987

MEMORANDUM OPINION

Monica Vasquez Parsons filed her petition for divorce from Paul G. Parsons.

Paul answered. Monica and her attorney failed to appear at trial, and the trial court

entered a post-answer default judgment against Monica. She filed a motion for new trial with accompanying evidence. The trial court denied the motion, and Monica

appealed.

In her sole issue, Monica contends that the trial court abused its discretion in

denying her motion for new trial because she presented evidence that her failure to

appear was not intentional or due to conscious indifference. We affirm.

Background

Monica married Paul in 2006. They did not have children. After 11 years of

marriage, Monica filed a petition for divorce. Among the grounds for divorce,

Monica claimed that the marriage had become “insupportable because of discord

or conflict of personalities.” Monica asserted that the court should award her a

disproportionate share of the marital estate for several reasons, including “fault in

the breakup of the marriage,” “disparity of earning power of the spouses,”

“wasting of community assets,” and “the size and nature of the separate estates of

the spouses.”

Paul answered and filed a counter-petition for divorce. He requested a just

and right division of the marital estate if the parties did not execute an agreement

for the division of their estate. Paul also requested confirmation that certain

property was his separate property and reimbursement from the community estate.

The trial court amended its initial scheduling order to allow the parties time

to attend mediation. When the parties appeared at the new trial setting, the trial

2 court rescheduled trial because the mediator had not recessed mediation. Both

parties received notice of a third trial setting. The parties scheduled a date to

resume mediation, but Monica and her attorney did not appear at mediation. The

mediator filed an impasse letter.

On the day of the third trial setting, Paul and his attorney appeared and

requested a default judgment when Monica and her attorney did not appear. Paul

testified about why the parties were dissolving their marriage. Paul’s attorney

informed the trial court that Monica’s attorney had not responded to his discovery

requests. The trial court admitted the exhibits introduced by Paul’s attorney. Paul’s

attorney also testified to his attorney’s fees. After considering the evidence, the

trial court entered a post-answer default judgment against Monica, granted the

divorce, and awarded Paul $15,612.61 for attorney’s fees. The trial court’s order

divided the marital estate and stated that the division was just and right.

Monica moved for a new trial, arguing that her non-appearance was due to a

mistake or accident because her attorney had a “conflict with another case,” she

tried to “finalize arrangements for the substitute attorney to cover the trial setting,”

yet the substitute attorney failed to appear. Monica explained that she did not

appear because she thought the trial had been reset. Monica’s motion was

supported by her attorney’s affidavit. Paul did not respond to the motion.

3 The trial court held a hearing on the motion for new trial. Monica’s attorney

explained that the substitute attorney who she had arranged to appear on her behalf

had broken her ankle. Although the substitute attorney texted her about the injury,

Monica’s attorney did not receive the message in time. The substitute attorney did

not appear at the new-trial hearing to testify. Based on the arguments of counsel

and evidence, and after noting that Monica’s motion for new trial said nothing

about a medical emergency, the trial court denied Monica’s motion for new trial.

Monica appeals.

Denial of Motion for New Trial

Monica argues that the trial court abused its discretion in denying her motion

for new trial because she presented evidence that her failure to appear was not

intentional or due to conscious indifference and because she meets the new-trial

test set forth in Craddock v. Sunshine Bus Lines, Inc., 133 S.W.2d 124, 126 (Tex.

1939).

A. Applicable law and standard of review

A post-answer default judgment is permissible when an answer is filed in a

case but a party fails to appear for trial. See Stoner v. Thompson, 578 S.W.2d 679,

682 (Tex. 1979). A post-answer default judgment is valid only if the defaulting

party received adequate notice of the trial setting or default-judgment hearing. In re

$475,001.16, 96 S.W.3d 625, 627 (Tex. App.—Houston [1st Dist.] 2002, no pet.)

4 (explaining notice is a requirement before entry of a post-answer default

judgment); TEX. R. CIV. P. 245 (providing that, “when a case previously has been

set for trial, the Court may reset said contested case to a later date on any

reasonable notice to the parties or by agreement of the parties”). If a party receives

post-answer notice of a trial setting and fails to appear, and the trial court grants a

post-answer default judgment, the party may move for a new trial, which should be

granted if she establishes all three of the Craddock prongs: (1) her non-appearance

resulted from an accident or mistake and not intentional or the result of conscious

indifference; (2) the motion for new trial alleges a meritorious defense; and (3)

granting the motion will not cause undue delay or otherwise injure the non-movant.

Dolgencorp of Tex., Inc. v. Lerma, 288 S.W.3d 922, 925 (Tex. 2009) (discussing

Craddock test); Lynch v. Lynch, 540 S.W.3d 107, 121 (Tex. App.—Houston [1st

Dist.] 2017, pet. denied) (same).

“A motion for new trial is addressed to the trial court’s discretion and the

court’s ruling will not be disturbed on appeal in the absence of a showing of an

abuse of discretion.” Cliff v. Huggins, 724 S.W.2d 778 (Tex. 1987). However, a

trial court abuses its discretion by denying a new trial when all three Craddock

elements are met. Dir., State Emps. Workers’ Comp. Div. v. Evans, 889 S.W.2d

266, 268 (Tex. 1994).

5 B. Contrary to Paul’s contention, Monica did not waive analysis under Craddock

The Texas Supreme Court has stated that its purpose “in adopting the

Craddock standard was to alleviate unduly harsh and unjust results at a point in

time when the defaulting party has no other remedy available.” Carpenter v.

Cimarron Hydrocarbons Corp., 98 S.W.3d 682, 686 (Tex. 2002) (citing Craddock,

133 S.W.2d at 126). The Craddock test does not apply when the rules of civil

procedure provide a defaulting party with a remedy. Id.

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Related

Dolgencorp of Texas, Inc. v. Lerma
288 S.W.3d 922 (Texas Supreme Court, 2009)
Stoner v. Thompson
578 S.W.2d 679 (Texas Supreme Court, 1979)
George v. Jeppeson
238 S.W.3d 463 (Court of Appeals of Texas, 2007)
Smith v. Babcock & Wilcox Construction Co.
913 S.W.2d 467 (Texas Supreme Court, 1996)
Cliff v. Huggins
724 S.W.2d 778 (Texas Supreme Court, 1987)
In the Matter of $475,001.16
96 S.W.3d 625 (Court of Appeals of Texas, 2002)
Craddock v. Sunshine Bus Lines, Inc.
133 S.W.2d 124 (Texas Supreme Court, 1939)
Carpenter v. Cimarron Hydrocarbons Corp.
98 S.W.3d 682 (Texas Supreme Court, 2002)
Sutherland v. Spencer
376 S.W.3d 752 (Texas Supreme Court, 2012)
Lynch v. Lynch
540 S.W.3d 107 (Court of Appeals of Texas, 2017)

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