Richard Wayne Sanders v. Catherine Michelle Bumgardner

CourtCourt of Appeals of Texas
DecidedJune 12, 1991
Docket03-90-00102-CV
StatusPublished

This text of Richard Wayne Sanders v. Catherine Michelle Bumgardner (Richard Wayne Sanders v. Catherine Michelle Bumgardner) 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
Richard Wayne Sanders v. Catherine Michelle Bumgardner, (Tex. Ct. App. 1991).

Opinion

IN THE COURT OF APPEALS, THIRD DISTRICT OF TEXAS,


AT AUSTIN




NO. 3-90-102-CV


RICHARD WAYNE SANDERS,


APPELLANT



vs.


CATHERINE MICHELLE BUMGARDNER,


APPELLEE





FROM THE DISTRICT COURT OF TRAVIS COUNTY, 126TH JUDICIAL DISTRICT


NO. 471,274, HONORABLE W. JEANNE MEURER, JUDGE PRESIDING




Appellant, Richard Wayne Sanders, by writ of error seeks review of a default judgment rendered in a paternity suit. Appellee, Catherine Michelle Bumgardner, filed her original petition before the birth of her daughter, alleging that appellant was the child's biological father. Her suit sought to establish a parent-child relationship between appellant and the child. She further sought appointment as the child's managing conservator, as well as orders for support of the child, for payment of health care expenses, and for attorney's fees. Appellant did not answer the suit and did not participate in the trial. By its final judgment, the trial court decreed that appellant was the child's father and ordered him to pay child support in the amount of $10,000 per month, as well as health care insurance, uninsured medical expenses, attorney's fees, and costs. Appellant argues that the trial court erred in rendering a default judgment because, due to defective service, it never acquired in personam jurisdiction over him. He further asserts that the evidence is either legally or factually insufficient to support the amount of child support ordered. We will affirm the judgment of the trial court.



Service was not Defective

In several points of error, appellant complains that the trial court erred in rendering a default judgment because it lacked in personam jurisdiction over him. Appellant complains that the service on him was defective because he was served with process by a person other than the person authorized to do so by the trial court.

Appellant lives in the State of Virginia. Under the Texas Rules of Civil Procedure, citation may be served on a nonresident by any disinterested person authorized to make oath of the fact. Tex. R. Civ. P. Ann. 108 (1979) (Rule 108). (1) No court authorization is required under the rules. Nevertheless, upon appellee's request, the trial court authorized "Doug Cramarty" to execute service on appellant. A review of the record reveals that the affidavit of the person requesting authorization as a private process server, the original return, and the amended return all appear to bear the same signature of either "D. Cromarty" or "D. Cramarty." Appellant complains that because of the variance, there is a lack of jurisdiction apparent on the face of the record that vitiates the trial court's default judgment and entitles him to a new trial. See McKanna v. Edgar, 388 S.W.2d 927, 928 (Tex. 1965).

The Family Code states that, in suits affecting the parent-child relationship, citation shall be issued and served as in other civil cases. Tex. Fam. Code Ann. § 11.09(c) (1986). Rule 103 states that citation may be served anywhere by (1) any sheriff or constable or other person authorized by law or (2) by any person authorized by law or by written order of the court. Rule 106(a) provides the methods whereby those authorized by Rule 103 may serve citation, while Rule 106(b) provides the method for obtaining alternate service requiring court authorization. Rule 107 directs the proper manner for executing the return of service. Finally, Rule 108 states the proper means for obtaining service over a nonresident, and states that the citation may be served by "any disinterested person competent to make oath of the fact in the manner as provided in Rule 106." Appellant does not dispute that, in the absence of any court order, Rule 108 controls the manner of serving nonresidents.

Here, pursuant to Rule 103, the trial court signed an order authorizing "Doug Cramarty" to act as a private server of process. The trial court did not prohibit service by anyone otherwise qualified by law, nor did it order any special manner of service. Appellant's complaint assumes that only the person authorized by the court order could execute service upon him. Even though no order was required, appellant argues that, because an order was signed, it must be complied with in every respect. We disagree with appellant; the order authorizing a private server did not disqualify anyone otherwise qualified under Rule 103 and Rule 108.

Appellant refers us to several cases in which appellate courts overturned default judgments because the pleadings, citation, return, or judgment misspelled or misidentified the defendant, not the server. See, e.g., Uvalde Country Club v. Martin Linen Supply Co., Inc., 690 S.W.2d 884 (Tex. 1985); De La Fuente v. Castillo, 740 S.W.2d 113 (Tex. App. 1987, no writ). The cases appellant cites are distinguishable. Unlike the present cause, these cases raise questions of whether it is just to impose a judgment against a person who was not served or against a person who was served, but not named in the complaint.

Similarly, we can distinguish this cause from cases involving publication or some other form of special or substituted service ordered by the court. See Rules 106(b), 109, and 109a; Mega v. Anglo Iron & Metal Co., 601 S.W.2d 501 (Tex. Civ. App. 1980, no writ); Cates v. Pon, 663 S.W.2d 99 (Tex. App. 1983, writ ref'd n.r.e.). In Mega, a default judgment was reversed when a Rule 106 order for substituted service was procured that authorized "A. R. 'Tony' Martinez," to serve citation because the return was signed by "A. R. Martinez, Jr." In Cates, the judgment was reversed when substituted service was authorized pursuant to Rule 106, to be performed by "Leonard Green," but the return was signed by "Lindsey E. Siriko." In both Mega and Cates, the court's order was necessary to obtain substituted service under Rule 106, and the record showed that the person executing service was not the person authorized by the court. In the present cause, however, service could be perfected without court order by anyone shown to be competent.

Appellant recognizes that a slight misspelling or slight discrepancy in the name may not require reversal of the judgment. He urges that "Doug Cramarty" is an entirely different name from "D. Cramarty" or "D. Cromarty," which difference establishes that an unauthorized person served process, making that service and the return of citation fatally defective. We are not persuaded that a material discrepancy exits in these names. Even if appellant is correct that the variance in name is material, however, we hold that the service was valid because the record reflects that the server was competent under Rule 108.

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

Related

Eggemeyer v. Eggemeyer
554 S.W.2d 137 (Texas Supreme Court, 1977)
Smith v. Smith
544 S.W.2d 121 (Texas Supreme Court, 1976)
Mega v. Anglo Iron & Metal Co. of Harlingen
601 S.W.2d 501 (Court of Appeals of Texas, 1980)
Eggemeyer v. Eggemeyer
535 S.W.2d 425 (Court of Appeals of Texas, 1976)
Eikenhorst v. Eikenhorst
746 S.W.2d 882 (Court of Appeals of Texas, 1988)
Pool v. Ford Motor Co.
715 S.W.2d 629 (Texas Supreme Court, 1986)
Stubbs v. Stubbs
685 S.W.2d 643 (Texas Supreme Court, 1985)
Rogers v. Rogers
561 S.W.2d 172 (Texas Supreme Court, 1978)
De La Fuente v. Castillo
740 S.W.2d 113 (Court of Appeals of Texas, 1987)
In Re King's Estate
244 S.W.2d 660 (Texas Supreme Court, 1951)
Jackson v. Van Winkle
660 S.W.2d 807 (Texas Supreme Court, 1983)
Anderson v. Anderson
770 S.W.2d 92 (Court of Appeals of Texas, 1989)
Smallwood v. Smallwood
625 S.W.2d 75 (Court of Appeals of Texas, 1981)
Carpenter v. White
624 S.W.2d 618 (Court of Appeals of Texas, 1981)
McKanna v. Edgar
388 S.W.2d 927 (Texas Supreme Court, 1965)
Morales v. Dalworth Oil Co., Inc.
698 S.W.2d 772 (Court of Appeals of Texas, 1985)
Uvalde Country Club v. Martin Linen Supply Co.
690 S.W.2d 884 (Texas Supreme Court, 1985)
Cates v. Pon
663 S.W.2d 99 (Court of Appeals of Texas, 1983)
Garza v. Alviar
395 S.W.2d 821 (Texas Supreme Court, 1965)
Bacon v. Kouri
696 S.W.2d 599 (Court of Appeals of Texas, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
Richard Wayne Sanders v. Catherine Michelle Bumgardner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-wayne-sanders-v-catherine-michelle-bumgardner-texapp-1991.