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Medrano v. Medrano

Citations: 810 S.W.2d 426; 1991 Tex. App. LEXIS 1583; 1991 WL 129723Docket: 04-90-00500-CV

Court: Court of Appeals of Texas; May 8, 1991; Texas; State Appellate Court

Narrative Opinion Summary

The case involves a dispute over unpaid child support where the appellant sought $20,500.00 from the appellee, covering arrears from August 5, 1983, to March 2, 1990. The trial court initially awarded this amount to the appellant but granted a $5,000.00 credit to the appellee for various payments made, including a car purchase and note payment. The appellant contested the reduction of arrearages by these credits, arguing that the Texas Family Code § 14.41(a) prohibits such offsets unless for actual child support during relinquished custody. The appellate court agreed, determining the trial court's credits were impermissible as they were not for actual child support. Furthermore, the appellant argued for prejudgment interest on the arrears, which the trial court had not awarded. The appellate court found that prejudgment interest is due on ascertainable sums, as child support arrears constitute a final judgment under § 14.41(a). Consequently, the appellate court reversed the trial court's judgment and remanded the case for the calculation of prejudgment interest and full payment of arrears without any credits. The appellee's failure to provide legal justification for the credits further supported this decision, resulting in a favorable outcome for the appellant.

Legal Issues Addressed

Entitlement to Prejudgment Interest on Child Support Arrearages

Application: The appellant was entitled to prejudgment interest on the child support arrears, which the trial court failed to award.

Reasoning: According to § 14.41(a), overdue child support constitutes a final judgment, and prejudgment interest is recoverable as a right for ascertainable sums due prior to judgment.

Finality of Child Support Arrearages

Application: The court confirmed that unpaid child support constitutes a final judgment, and the arrears must be confirmed upon request without modification.

Reasoning: According to Texas Family Code § 14.41(a), unpaid child support constitutes a final judgment, and the court must confirm arrears upon request.

Impermissible Reduction of Child Support Arrearages

Application: The trial court's decision to apply a credit reducing child support arrearages by $5,000 was reversed as it violated the statute prohibiting such reductions not for actual child support.

Reasoning: The court determined that the offset applied by the trial judge to reduce the appellee's child support arrearage by $5,000 was impermissible under TEX.FAM. CODE § 14.41(a), as it was not for actual child support.