The following are summaries of selected civil opinions issued by the Third Court of Appeals during October 2024. The summaries are an overview; please review the entire opinion. Subsequent histories are current as of November 11, 2024.
FAMILY LAW: Court affirms modification ordering child support.
Doyle v. Doyle, No. 03-22-00691-CV (Tex. App.—Austin Oct. 11, 2024, no pet. h.) (mem. op.).
The trial court granted mother’s request to modify the parties’ divorce decree that did not order child support and ordered father to pay child support. Mother established that the decree was signed during the COVID pandemic while she worked on commission in furniture sales when sales were very high. After the pandemic subsided, sales greatly decreased, and mother’s income dropped significantly. The court of appeals rejected father’s argument that to support a modification, mother must present evidence of her income at the time of divorce to show a material and substantial change in circumstances. The court concluded that mother’s evidence of a significant decrease in income allowed the trial court to meaningfully compare movant’s financial circumstances when the decree was signed with her current situation. The court affirmed.