Randy Moore v. Sandra Faye Moore

CourtCourt of Appeals of Texas
DecidedOctober 22, 2019
Docket01-18-00547-CV
StatusPublished

This text of Randy Moore v. Sandra Faye Moore (Randy Moore v. Sandra Faye Moore) 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
Randy Moore v. Sandra Faye Moore, (Tex. Ct. App. 2019).

Opinion

Opinion issued October 22, 2019

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-18-00547-CV ——————————— RANDY MOORE, Appellant V. SANDRA FAYE JORDAN, Appellee

On Appeal from the 311th District Court Harris County, Texas Trial Court Case No. 2016-78225

MEMORANDUM OPINION

Appellant, Randy Moore, contests the division of property contained in the

final decree of divorce dissolving his marriage to Sandra Faye Jordan. In three issues

on appeal, Moore contends the trial court abused its discretion by: (1) characterizing certain property as community property rather than as his separate property, (2)

denying his motion for new trial, and (3) awarding a disproportionate share of the

community estate to Jordan. We affirm.

BACKGROUND

Moore and Jordan were married for over 10 years when Jordan filed for

divorce. There were no children of the marriage. Jordan requested that she be

awarded a disproportionate share of the community estate based upon Moore’s fault

in the breakup of the marriage. Moore filed a counterpetition, alleging that the

marriage was insupportable and that Jordan had committed adultery.

The trial court held a bench trial, at which both parties testified. Jordan was

represented by counsel; Moore represented himself pro se.

1. Grounds for the Divorce and Moore’s Separate Property

After hearing evidence from both parties, the trial court (1) granted the divorce

based on insupportability and Moore’s infidelity and cruel treatment toward Jordan,

and (2) found that Jordan was entitled to a disproportionate share of the community

property. The trial court also confirmed as Moore’s separate property 100% of his

retirement account earned prior to the date of the marriage and real property located

at 2055 Nora Street, Beaumont, TX and 7605 Glass Street, Houston, TX.

2. The Division of Community Property

The trial court divided the community property as follows:

2 Assets to Jordan: (1) personal effects in her possession, (2) cash in her

possession or subject to her sole control, (3) a vehicle, (4) 100% of her retirement

accounts, (5) 50% of Moore’s retirement accounts accruing after the date of their

marriage, and (6) 100% of the marital home located at 7825 and 7829 Pointer Street,

Houston, TX.

Debts to Jordan: (1) all debts incurred by her unless otherwise specified, (2)

all credit card debt in her name solely, and (3) the mortgage and taxes associated

with the marital residence located at 7825 and 7829 Pointer Street, Houston, TX.

Assets to Moore: (1) personal effects in his possession, (2) cash in his

possession or subject to his sole control, (3) five vehicles, (4) 50% of his retirement

accounts accruing after the date of the marriage, (5) Lots 1 & 2 on Levander Street

and a lot on Tampico Street.

Debts to Moore: (1) all debts incurred by him unless otherwise specified, (2)

all credit card debt in his name only, (3) the mortgage and taxes associated with lots

1 & 2 on Levander Street and the lot on Tampico Street.

3. Motion for New Trial

Dissatisfied with the judgment, Moore hired counsel to file a motion for new

trial. His motion requested that the trial court “grant a new trial in the interest of

justice and fairness” so that he could “relitigate the issue of the court’s rendition and

awarding Sandra Faye Jordan the properties located at 7829 Pointer Street and 7825

3 Pointer Street, Houston, Texas 77016.” Moore attached an affidavit to his motion

for new trial in which he claimed that the Pointer Street properties were his separate

property because he entered into an earnest money contract for their purchase before

the date of the marriage. His affidavit requested “that [the] Court grant me a new

trial in the interest of justice, so that I may present the proper evidence to rebut any

presumption that the property located at 7829 Pointer St. and 7825 Pointer St.,

Houston, Texas 77016 is community property[.]”

The trial court held a hearing on the motion for new trial, at which both Moore

and Jordan testified. Moore also introduced an earnest money contract for the

Pointer Street properties, which he claimed showed that inception of title occurred

before the date of the marriage.

The trial court denied Moore’s motion for new trial and this appeal followed.

CHARACTERIZATION OF PROPERTY

In his first issue on appeal, Moore contends that “the trial court abuse[d] its

discretion in characterizing the properties located at 7825 and 7829 Pointer St. as

community property.”

1. Standard of Review and Applicable Law

“We review a trial court’s division of property under an abuse of discretion

standard.” Moroch v. Collins, 174 S.W.3d 849, 857 (Tex. App.—Dallas 2005, pet.

denied) (citing LaFrensen v. LaFrensen, 106 S.W.3d 876, 878 (Tex. App.—Dallas

4 2003, no pet.)). “[I]n family law cases, the abuse of discretion standard of review

overlaps with the traditional sufficiency standard of review; as a result, legal and

factual insufficiency are not independent grounds of reversible error, but instead

constitute factors relevant to our assessment of whether the trial court abused its

discretion.” Moroch, 174 S.W.3d at 857 (citing Boyd v. Boyd, 131 S.W.3d 605, 611

(Tex. App.—Fort Worth 2004, no pet.); Beaumont Bank N.A. v. Buller, 806 S.W.2d

223, 226 (Tex. 1991)). Thus, to determine whether the trial court abused its

discretion because the evidence is legally or factually insufficient to support the trial

court’s decision, we engage in a two-pronged inquiry: (1) did the trial court have

sufficient evidence upon which to exercise its discretion, and (2) did the trial court

err in its application of that discretion. Moroch, 174 S.W.3d at 857. “The applicable

sufficiency review comes into play with regard to the first question.” Id. (citing

Boyd, 131 S.W.3d at 611). We must then determine whether, based on the evidence,

the trial court made a reasonable decision. Id. Stated another way, the party

challenging the trial court’s characterization must first establish error by challenging

the legal or factual sufficiency of the evidence to support the property’s

characterization and must then show that because of the mischaracterization, the trial

court abused its discretion. See Viera v. Viera, 331 S.W.3d 195, 207 (Tex. App.—

El Paso 2011, no pet.).

5 Property possessed by either spouse during or on dissolution of marriage is

presumed to be community property. TEX. FAM. CODE § 3.003(a)). To overcome the

community property assumption, a party claiming marital property as separate

property must prove the claim with clear and convincing evidence. Id. § 3.003(b).

Clear and convincing evidence is defined as that “measure or degree of proof that

will produce in the mind of the trier of fact a firm belief or conviction as to the truth

of the allegations sought to be established.” TEX. FAM. CODE § 101.007; see also

Garza v. Garza, 217 S.W.3d 538, 548 (Tex.

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