In The Interest of K.M.C. a Child

Shantel Berry-Conway brings a restricted appeal from the default judgment in a suit for divorce and child custody.  In her issue on appeal, appellant contends the default judgment must be reversed because the return

Restricted Appeals in Texas

The availability of relief by restricted appeal is primarily governed by Texas Rule of Appellate Procedure 30, which states: “A party who did not participate—either in person or through counsel—in the hearing that resulted

Lozano v. Alvarez

On December 11, 2013, the United States Supreme Court held oral arguments in Lozano v. Alvarez. The facts of the case are as follows: “Diana Alvarez and Manuel Lozano, two native Columbians, met while

Presumptions in Modifications

This article explores presumptions in modifications.  A presumption is a legal standard imposed by statute that normally applies to a case unless it is rebutted.  In original family law cases, these presumptions are found