OPINION
SAM BASS, Justice.
This appeal concerns the validity of a settlement and release agreement for past and future child support and an order denying appellant’s motion to modify support, based on materially and substantially changed circumstances.
We affirm.
Houson D. Williams, appellant, and Sherry Yvonne Patton, appellee, were divorced on December 2, 1974. Appellee was named managing conservator of Amy Diane Williams. Appellant was ordered to pay child support of $121 per month. Appellant did not pay child support from 1977 through 1985.
On October 15, 1985, appellee filed a motion for contempt on child support, and a motion to increase child support. Appellant’s arrearage was $9,885.
On May 6, 1986, the parties entered into a settlement and release agreement whereby appellant agreed to pay $2,850 for past due payments, agreed to increase the amount of child support to $325 per month for a period of 18 months and, thereafter, in the sum of $350 per month, until the child reached the age of 18 years or was emancipated. In return, appellee was to [528] dismiss her contempt action against appellant. Appellant contends this agreement was approved by the trial court on May 13, 1986. On May 13, 1986, the trial court entered an order entitled “agreed order modifying prior order,” signed by Williams’ and Patton’s respective attorneys, agreeing as to “form only,” and an order to dismiss the contempt action. The modifying order increased the monthly child support payments; however, it did not reference the settlement agreement or acknowledge its existence in any manner. No one has challenged the court’s entry of an “automatic increase” in child support payments, and, thus, this Court will not consider whether that portion of the trial court’s order is valid. The settlement agreement is found as an exhibit in the statement of facts.
The child moved into appellant’s home in November 1987, and appellant discontinued making child support payments the following month. On June 10, 1988, the child left appellant’s residence and moved in with her boyfriend. In August 1988, appellee filed contempt proceedings against appellant. Appellant filed a motion to modify his support obligation and an original petition for breach of the settlement and release agreement. The appellee filed a cross-action on the breach of the settlement agreement.
After hearing all pending motions and arguments, the court found that the settlement and release agreement executed by the parties is void because: (1) it is against public policy; (2) the parties cannot reduce the amount of child support arrearage; (3) there was no court approval of the agreement; and (4) there was no consideration for the agreement. The court denied appellant’s motion to modify and entered a take-nothing judgment on both appellant’s and appellee’s breach of contract actions.
In his first two points of error, appellant challenges the trial court’s conclusion that the settlement and release agreement is void and unenforceable.
The settlement and release agreement entered into between the parties states in relevant part:
[I]n consideration of the payment of the sum of $2,850.00 by HOUSON D. WILLIAMS, JR. to SHERRY YVONNE (WILLIAMS) BAILES, payable in full upon the execution of this agreement, and for the further consideration of the agreement of HOUSON D. WILLIAMS, JR. to an Agreed Order Modifying Prior Order whereby the Decree of Divorce of December 2, 1974, shall be modified in certain respects, including increasing the support payment by HOUSON D. WILLIAMS, JR. for the use, benefit and support of AMY DIANE WILLIAMS to the amount of $325.00 per month for eighteen (18) months ... and thereafter in the amount of $350.00 per month until the said child reaches the age of eighteen (18) years ... SHERRY YVONNE (WILLIAMS) BAILES does hereby RELEASE AND DISCHARGE HOUSON D. WILLIAMS, JR. ... of and from any and all claims, demands, damages, actions, causes of action ... arising from the obligation of HOUSON D. WILLIAMS, JR. for the payment of child support ... for the period from and after December 2, 1974 to March 31, 1986.
Parents of minor children in Texas do not have the right or the power to agree to a modification of a court decree for future child support without court approval. In re McLemore, 515 S.W.2d 356, 357 (Tex.Civ.App.-Dallas 1974, no writ); see also McIntyre v. McFarland, 529 S.W.2d 857, 859 (Tex.Civ.App.-Tyler 1975, no writ).
Appellant does not challenge the rule of law that divorced parents may not modify the future support obligation of the noncustodial spouse without court approval. However, appellant asserts that Texas should follow the “majority” of other states that uphold settlement and release agreements between former spouses for accrued child support. See, e.g., Andersen v. Andersen, 89 Idaho 551, 407 P.2d 304, 307 (1965); Brannock v. Brannock, 104 N.M. 416, 722 P.2d 667, 670 (N.M.Ct.App.1985), aff'd, 104 N.M. 385, 722 P.2d 636 (N.M.1986); Miller v. Miller, 29 Or.App. 723, 565 P.2d 382, 385 (Oregon Ct.App.1977); Hartman v. Smith, 100 Wash.2d 766, 674 P.2d 176, 178 (1984). The out-of-[529] state cases cited by appellant treat delinquent support payments as a debt owed to the managing conservator because she has already used her own funds to pay for the support of the children, and provide that a former wife may, for sufficient consideration, release the former husband from the obligation to make support payments previously owing.
We note that the Supreme Court of. Texas has stated that it does not agree with the characterization of unpaid child support as a debt prior to its reduction to judgment. Adair v. Martin, 595 S.W.2d 513, 515 (Tex.1980).1 It has not determined whether or not, on reduction to final judgment under Tex.Fam.Code Ann. § 14.41(a) (Vernon Supp.1990), the arrearages may then be classified as a debt, even though the judgment may be enforced in any manner provided by law.
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OPINION
SAM BASS, Justice.
This appeal concerns the validity of a settlement and release agreement for past and future child support and an order denying appellant’s motion to modify support, based on materially and substantially changed circumstances.
We affirm.
Houson D. Williams, appellant, and Sherry Yvonne Patton, appellee, were divorced on December 2, 1974. Appellee was named managing conservator of Amy Diane Williams. Appellant was ordered to pay child support of $121 per month. Appellant did not pay child support from 1977 through 1985.
On October 15, 1985, appellee filed a motion for contempt on child support, and a motion to increase child support. Appellant’s arrearage was $9,885.
On May 6, 1986, the parties entered into a settlement and release agreement whereby appellant agreed to pay $2,850 for past due payments, agreed to increase the amount of child support to $325 per month for a period of 18 months and, thereafter, in the sum of $350 per month, until the child reached the age of 18 years or was emancipated. In return, appellee was to [528] dismiss her contempt action against appellant. Appellant contends this agreement was approved by the trial court on May 13, 1986. On May 13, 1986, the trial court entered an order entitled “agreed order modifying prior order,” signed by Williams’ and Patton’s respective attorneys, agreeing as to “form only,” and an order to dismiss the contempt action. The modifying order increased the monthly child support payments; however, it did not reference the settlement agreement or acknowledge its existence in any manner. No one has challenged the court’s entry of an “automatic increase” in child support payments, and, thus, this Court will not consider whether that portion of the trial court’s order is valid. The settlement agreement is found as an exhibit in the statement of facts.
The child moved into appellant’s home in November 1987, and appellant discontinued making child support payments the following month. On June 10, 1988, the child left appellant’s residence and moved in with her boyfriend. In August 1988, appellee filed contempt proceedings against appellant. Appellant filed a motion to modify his support obligation and an original petition for breach of the settlement and release agreement. The appellee filed a cross-action on the breach of the settlement agreement.
After hearing all pending motions and arguments, the court found that the settlement and release agreement executed by the parties is void because: (1) it is against public policy; (2) the parties cannot reduce the amount of child support arrearage; (3) there was no court approval of the agreement; and (4) there was no consideration for the agreement. The court denied appellant’s motion to modify and entered a take-nothing judgment on both appellant’s and appellee’s breach of contract actions.
In his first two points of error, appellant challenges the trial court’s conclusion that the settlement and release agreement is void and unenforceable.
The settlement and release agreement entered into between the parties states in relevant part:
[I]n consideration of the payment of the sum of $2,850.00 by HOUSON D. WILLIAMS, JR. to SHERRY YVONNE (WILLIAMS) BAILES, payable in full upon the execution of this agreement, and for the further consideration of the agreement of HOUSON D. WILLIAMS, JR. to an Agreed Order Modifying Prior Order whereby the Decree of Divorce of December 2, 1974, shall be modified in certain respects, including increasing the support payment by HOUSON D. WILLIAMS, JR. for the use, benefit and support of AMY DIANE WILLIAMS to the amount of $325.00 per month for eighteen (18) months ... and thereafter in the amount of $350.00 per month until the said child reaches the age of eighteen (18) years ... SHERRY YVONNE (WILLIAMS) BAILES does hereby RELEASE AND DISCHARGE HOUSON D. WILLIAMS, JR. ... of and from any and all claims, demands, damages, actions, causes of action ... arising from the obligation of HOUSON D. WILLIAMS, JR. for the payment of child support ... for the period from and after December 2, 1974 to March 31, 1986.
Parents of minor children in Texas do not have the right or the power to agree to a modification of a court decree for future child support without court approval. In re McLemore, 515 S.W.2d 356, 357 (Tex.Civ.App.-Dallas 1974, no writ); see also McIntyre v. McFarland, 529 S.W.2d 857, 859 (Tex.Civ.App.-Tyler 1975, no writ).
Appellant does not challenge the rule of law that divorced parents may not modify the future support obligation of the noncustodial spouse without court approval. However, appellant asserts that Texas should follow the “majority” of other states that uphold settlement and release agreements between former spouses for accrued child support. See, e.g., Andersen v. Andersen, 89 Idaho 551, 407 P.2d 304, 307 (1965); Brannock v. Brannock, 104 N.M. 416, 722 P.2d 667, 670 (N.M.Ct.App.1985), aff'd, 104 N.M. 385, 722 P.2d 636 (N.M.1986); Miller v. Miller, 29 Or.App. 723, 565 P.2d 382, 385 (Oregon Ct.App.1977); Hartman v. Smith, 100 Wash.2d 766, 674 P.2d 176, 178 (1984). The out-of-[529] state cases cited by appellant treat delinquent support payments as a debt owed to the managing conservator because she has already used her own funds to pay for the support of the children, and provide that a former wife may, for sufficient consideration, release the former husband from the obligation to make support payments previously owing.
We note that the Supreme Court of. Texas has stated that it does not agree with the characterization of unpaid child support as a debt prior to its reduction to judgment. Adair v. Martin, 595 S.W.2d 513, 515 (Tex.1980).1 It has not determined whether or not, on reduction to final judgment under Tex.Fam.Code Ann. § 14.41(a) (Vernon Supp.1990), the arrearages may then be classified as a debt, even though the judgment may be enforced in any manner provided by law.
Sectlon 14.41(a) of the Texas Family Code provides that periodic child support payments not timely made constitute a “final judgment.”2 However, the court, on motion under this section, was required to confirm this “final judgment” as to the amount of arrearage, and in doing so, had to consider offsets as provided by Tex.Fam. Code Ann. § 14.41(c) (Vernon 1986), but could not reduce or modify the amount of the child support arrearage in its confirmation of this “final judgment.” Tex.Fam. Code Ann. § 14.41(d) (Vernon 1986).3 Further, former Tex.Fam.Code Ann. § 14.41(b),4 applicable at the time of the hearing, provided that the court retained jurisdiction to “enter judgment” for past-due child support payments, if a motion to render judgment was filed within two years:5 (1) after the child becomes an adult; or (2) the date the child support obligation terminates.
[530] It is evident that the legislature contemplated the continued supervision of the court over arrearages even though they constituted a “final judgment.” Therefore, we hold that under Tex.Fam.Code Ann. § 14.41(a), the child support arrearages remain under the supervision of the court and may not be modified by the parties until the court either (1) reduces the unpaid child support to written judgment, or (2) loses jurisdiction after the child reaches majority or two years after the date on which the child support obligation terminated pursuant to the decree or order or by operation of law. Former Tex.Fam.Code Ann. § 14.41(b). After these occurrences, the parties could enter into a contract with regard to the payment of the judgment for arrearages without the necessity of court approval.
In this case, the contract was entered into before the trial court reduced the unpaid child support to written judgment against appellant for the amount due and owing under § 14.41(a). Because the child support arrearage still remained under the supervision of the court, the agreement, which attempts to modify the amount of arrearages, is void and unenforceable.
Points of error one and two are overruled.
In points of error three and four, appellant contends the trial court abused its discretion in denying appellant’s motion to modify because the uncontroverted evidence established as a matter of law that the minor child’s circumstances had materially and substantially changed. Appellant also argues that the trial court’s implied finding that no material and substantial change in the minor child’s circumstances had occurred was so contrary to the overwhelming weight and preponderance of the credible evidence as to be manifestly unjust.
A trial court is accorded broad discretion in determining whether a movant has met his burden of establishing a material and substantial change in circumstances to warrant modification, and the trial court’s order granting or denying the requested modification will be reversed only on a showing of abuse of discretion. Williams v. Williams, 596 S.W.2d 245, 247 (Tex.Civ.App.-Houston [14th Dist.] 1980, no writ). An abuse of discretion occurs when the trial court acts without reference to any guiding principles of law. Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238, 241 (Tex.1985), cert. denied, 476 U.S. 1159, 106 S.Ct. 2279, 90 L.Ed.2d 721 (1986).
On September 20, 1988, appellant filed a motion to modify the parent-child relationship, seeking to modify the order dated May 13, 1986. Appellant pled that child support payments previously ordered be “reduced and ceased altogether because the child has ceased to reside with Respondent and is in fact emancipated.” The trial court made no findings of fact in support of its conclusion of law that the “Respondent’s Motion to Modify should be denied.”
The question of whether a child is “emancipated,” and thus not entitled to child support, by voluntarily leaving the home and custody of her parents to live with an unrelated person, has not been established by Texas case law. Appellee relies on Laird v. Swor, 737 S.W.2d 601, 603 (Tex.App.-Beaumont 1987, no writ) where the court refused to consider an 18-year-old child “emancipated” after he moved from his mother’s home to live with and care for an aged relative. The instant case is readily distinguishable. Our facts do not fit clearly within case law that does consider a minor child emancipated once the child marries. See id. at 602. There has been a substantial change of circumstances in the parent-child relationship since the date of the agreed order of May 13, 1986. Where the ex-wife/managing conservator is no longer furnishing the degree of service to the minor child that she did at the time of the order on child support, this is itself a material and substantial change in circumstances requiring a reallocation of support obligations. Labowitz v. Labowitz, 542 S.W.2d 922, 925 (Tex.Civ.App.-Dallas 1976, no writ). The question remains, however, whether it was an abuse of discretion for the trial court to deny appellant’s motion to modify support [531] obligations on this basis. Judge 0. Bass denied appellant’s motion on December 9, 1988, five months before the minor child turned 18 and was officially emancipated. A minor child needs financial assistance, and it is not an abuse of discretion for a trial court to force the former husband to assume his responsibility for his daughter’s support for an additional five months, whether she be living with her boyfriend, mother, or father.
Points of error three and four are overruled.
The judgment is affirmed.
MIRABAL, J., dissents.