Requests for Admission in Texas: The Quiet Trap for Pro Se Litigants
Miss the deadline on requests for admission in Texas and every statement is deemed admitted. What Wheeler v. Green held, and how to withdraw deemed admissions.
Schooley
Rule 194a Request for Disclosure: The Texas Discovery Rule Most Pro Se Litigants Miss
There’s a trap in Texas discovery that catches self-represented people constantly, and it comes from reading the wrong rule. The automatic disclosure rule everyone quotes does not apply to your case If you go looking online, you’ll find a bunch of articles saying that since 2021 Texas requires automatic initial disclosures. Both sides have to … Read more
Text Message Evidence in Texas Family Court: Getting Your Screenshots Admitted
I see this one constantly. Somebody shows up with a three-inch binder of text message screenshots, absolutely certain it’s going to end the case, and then it never gets in front of the judge because they don’t know how to admit it. Having text message evidence in Texas family court and getting that evidence admitted … Read more
Your Decree Is Too Vague to Enforce — How a Motion to Clarify Fixes It
You file your enforcement motion, you’ve documented everything, you show up ready, and the other side’s attorney stands up and says the order isn’t specific enough to be enforced by contempt. And the judge agrees with them. That’s a rough afternoon, and I’ve watched people take it as a loss on the merits when it … Read more
Enforcing Child Support in Texas: Arrears, Confirmation, Wage Withholding, and the AG
Unpaid child support is the most common enforcement problem I deal with, and it’s also the one where people wait the longest before doing anything. They don’t want to be the bad guy. They keep hoping it’ll turn around. And two years later they’re owed twenty thousand dollars and they’ve convinced themselves it’s too late … Read more
Why Most Pro Se Enforcement Motions Get Denied — And How to Draft One That Doesn’t
I’ve read a lot of enforcement motions written by self-represented parents, and I can usually tell in the first paragraph whether it’s going to survive. Not because the facts are bad. Usually the facts are terrible, in the sense that the other parent has genuinely been doing something outrageous for months. The motions fail on … Read more
Your Child Wants to Live With You — What a Texas Judge Can Actually Do About It
This is the question I probably get asked more than any other, and it usually comes with a lot of hope attached to it. My daughter is thirteen and she wants to live with me. Doesn’t that settle it? I want to answer this carefully, because there’s a real legal mechanism here and it matters, … Read more
Modifying Child Support in Texas: The 3-Year, 20%, and $100 Triggers
Child support modification is one of the few places in Texas family law where the legislature gave you a genuinely simple path, and hardly anybody uses it. Most people assume they have to prove a material and substantial change, they can’t figure out how to prove one, and they never file. There’s a second door, … Read more
The One-Year Rule: Why Your Modification Needs an Affidavit Under Family Code 156.102
Here’s a scenario I see several times a year, and it never stops being painful. Somebody comes to me eight months after their order was signed. Things have gone badly at the other parent’s house, they’ve got real concerns, and they filed a modification asking to become the primary parent. And the court denied it … Read more
Community or Separate? The Property Question That Decides Your Texas Divorce
If you only learn one thing about the money side of a Texas divorce, make it this. Everything the two of you possess when the divorce is filed is presumed to be community property, and if you think some of it is yours alone, the burden is on you to prove it. Not on your … Read more