Samantha Tianne Erickson v. Lee Robert Erickson

Court of Appeals of Texas·Decided September 29, 2020·No. 01-19-00481-CV·Published

Opinion

Opinion issued September 29, 2020

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-19-00481-CV ——————————— IN RE A.T.E., A CHILD

On Appeal from the 308th District Court Harris County, Texas Trial Court Case No. 2013-10540

MEMORANDUM OPINION

This is a custody dispute. Lee Erickson and Samantha Erickson have one

child, A.T.E., who we will refer to as Anna.1 When Lee and Samantha2 divorced in

2012, Samantha was named sole managing conservator, and Lee was named

1 We refer to the child by a pseudonym to protect her privacy. 2 We will refer to the parents by their first names because they share the same last name. possessory conservator and granted only supervised visits with Anna. In 2016, Lee

petitioned to modify the custody order to allow unsupervised visits. Samantha

resisted the modification, arguing that Lee failed to establish, as a threshold matter,

a material and substantial change in circumstances to warrant a modification and,

even if he had, Lee failed to meet his burden to obtain unsupervised visitation with

Anna. The trial court held an evidentiary hearing and granted the modification.

In five issues, Samantha contends the trial court abused its discretion in

granting the modification. Because we conclude Lee failed to meet his burden to

establish a material and substantial change in circumstances, we hold that the trial

court abused its discretion in granting a modification of the custody order and reverse

the trial court’s judgment.

Background

Lee received a DWI in 2012 while driving a company vehicle. Describing the

DWI as the latest in a string of events evincing Lee’s on-going issues with alcohol,

Samantha filed a Suit Affecting Parent Child Relationship (SAPCR) that sought to

limit Lee’s access to Anna. Samantha attached her own multi-page affidavit to her

petition in which she recounted numerous events during their marriage when Lee

became intoxicated and required law enforcement or family assistance to rectify the

situation. Examples included turning on the stovetop burner with an empty pot above

the open flame and then, because of his intoxication, walking away with the fire still

2 burning; passing out in public and having the police call Samantha in the middle of

the night to come pick him up from the jail while Samantha was caring for a two-

year-old child alone at home; passing out repeatedly in the family home and vehicle;

urinating in inappropriate locations in the family home because his intoxication

prevented him from finding the bathroom; and mixing alcohol with prescription and

illegal drugs. Samantha requested that she be named sole managing conservator, that

Lee be granted only supervised visits with Anna, and that Lee be prohibited from

drinking during the 12 hours preceding periods of supervised visitation and during

supervised visitation.

Having returned to his home country of Canada after losing his job and work

visa, Lee did not contest the suit. A default judgment was entered. Samantha was

named sole managing conservator, Lee was named possessory conservator, and Lee

was limited to supervised visits. Shortly thereafter, Lee and Samantha divorced.

Unlike with the SAPCR, both parties participated in the divorce litigation. It

concluded with an Agreed Final Decree of Divorce. The agreed divorce decree

incorporated the terms of the earlier SAPCR order and attached that order as an

exhibit. Under the terms of the divorce decree, Lee agreed to be limited to supervised

visitation and to be prohibited from consuming alcohol before or during his visits

with Anna. The decree specified that visitation would be supervised by Samantha

“or any responsible adult designated by” Samantha. As with any other custody order,

3 the agreed final decree of divorce is res judicata as to Anna’s best interests at the

time of its entry. Knowles v. Grimes, 437 S.W.2d 816, 817 (Tex. 1969).

Over the next three years, Lee traveled to Texas to visit Anna under

Samantha’s supervision. At times, Lee requested that his mother or someone else be

permitted to supervise instead, but Samantha always refused. Eventually, Samantha

began a new relationship. At times, that person and his children would come with

Samantha and Anna to the supervised visits.

In 2016, Lee filed a petition to modify the custody order. The modifications

he sought were to be named joint managing conservator, to have unsupervised visits

with Anna, and to be permitted to consume alcohol before and during the visits.

After numerous procedural events, including an unauthorized attempt at an

interlocutory appeal, the matter was set for an evidentiary hearing in May 2019.

There were three witnesses: Lee, Samantha, and Lee’s new wife, Elizabeth.

Both sides submitted extensive documentary evidence, including photographs,

screenshots of Facebook posts, screenshots of text messages, and child support

documents. Samantha argued that Lee’s Facebook posts—many of which centered

on a theme of alcohol—showed that alcohol continued to play a central role in Lee’s

life and his alcohol use had not diminished. Lee argued he did not have an issue with

alcohol and the restrictions were unnecessary. During the proceeding, the trial court

ordered Lee to submit to a drug and alcohol test: the test results were negative.

4 Following the hearing, the trial court entered a modified custody order that

permitted Lee unsupervised visits with Anna with a detailed and specific step-up

progression that would eventually permit international travel. The order maintained

the prohibition against alcohol consumption before and during the visits.

Samantha appealed. We referred the parties to mediation, but Lee objected.

After Lee’s objection, we notified the parties that the case would be resolved on the

briefs.3

Substantial and Material Change: Threshold Issue

In her third and fourth issues, Samantha contends the trial court abused its

discretion in modifying the custody order because there was factually and legally

insufficient evidence of a substantial and material change in circumstances to

warrant disturbing the existing custody order.

A. Applicable law

A final judgment resolving custody issues, like Lee and Samantha’s agreed

final divorce decree, is res judicata on the issue of what is in the child’s best interests

at the time the judgment was entered. Knowles, 437 S.W.2d at 817. Texas has a long-

standing public policy against repeated re-litigation of custody issues. See id.; Smith

v. Karanja, 546 S.W.3d 734, 738 (Tex. App.—Houston [1st Dist.] 2018, no pet.).

3 Samantha filed post-submission materials that were not in the record. We did not consider these materials. 5 The rationale for the policy is that custody modifications disrupt the stability of the

home and the surroundings of the child subject to the custody order. See Knowles,

437 S.W.2d at 817; Smith, 546 S.W.3d at 738.

Consistent with this policy, parents who want to alter the terms of an existing

custody order are required, as a threshold matter, to demonstrate that a substantial

and material change in circumstances has occurred. See Knowles, 437 S.W.2d at

817; Smith, 546 S.W.3d at 738.

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