Texas court upholds $93,778 judgment for grandfather caring for three children

A Texas grandfather who became the primary caregiver of his three grandchildren following their father's death has won a legal battle against their mother over unpaid child support and medical bills. Last week, a Texas appeals court upheld a $93,778 judgment against the mother, including more than $65,000 in medical expenses. As detailed in the court ruling available on Justia, Rain Levy Minns Udall and her husband divorced in 2016, with both retaining legal responsibility for their three children. Soon afterwards, the father was diagnosed with cancer. He died in November 2017. Four years later, the children's grandfather, Michael Minns, went to court seeking responsibility for their care. His first application concerned only the eldest child, but he later asked to take responsibility for all three. The court eventually granted him sole managing conservatorship, making him the children's primary legal caregiver. The court had also ordered Udall to contribute financially towards her children's upbringing and healthcare. When Minns claimed that these payments were not being made, he returned to court seeking the outstanding money. How payment dispute reached court At a hearing, the trial court examined the payments required from Udall and what she had actually paid. It found seven instances of unpaid monthly child support and seven instances of unpaid cash medical support. There were also 118 violations relating to medical expenses. The court further found that an earlier child-support judgment of $14,192.71 remained unpaid. It awarded Minns another $93,778.44. Of this amount, $65,532.40 concerned medical expenses that had not been reimbursed. The remaining sum covered $13,136.48 in unpaid child support, $643.31 in medical support and $14,467.25 in lawyers' fees. Udall appealed, arguing that the order should not stand. Her objections centred on the medical expenses and whether the grandfather had followed the required process before asking her to pay. Mother questioned medical expenses The medical bills covered treatment received by the children between July 2021 and March 2024. The court records also noted that all three children had significant mental healthcare needs alongside physical healthcare expenses. Under the arrangements made in 2021, Udall was responsible for all healthcare expenses not covered by insurance if she was not providing the children's insurance. The later custody order continued to place responsibility for these costs on her, subject to provisions concerning the deceased father's estate. Despite those arrangements, Minns asked the court to recover only half of the outstanding medical expenses. Udall maintained that he had not given her the necessary documents on time. She also raised concerns about the choice of healthcare providers and argued that she had not been properly consulted about treatment decisions. The appeals court examined these objections but found that she had not identified particular bills that were unsupported or incorrect. It also found no requirement making prior consultation a condition for recovering the expenses. Another important question was whether late paperwork meant the mother no longer had to pay. The court explained that the orders allowed additional time for reimbursement when documents were supplied late. How grandfather supported his claim Minns had presented detailed spreadsheets showing the healthcare expenses incurred for each child. The records included the treatment dates, providers, amounts paid and the money he was seeking from Udall. They also showed when the relevant information had been sent to her and when payment was expected. During the hearing, Minns confirmed that the records reflected the expenses he had incurred and the reimbursements received. He said Udall had made only one payment towards those medical expenses. The appeals court found it significant that Udall had not disputed that the treatment expenses were incurred. Nor had she challenged individual entries in the spreadsheets or provided specific examples of inadequate supporting documents. The judges therefore concluded that the grandfather's records, together with his testimony, provided sufficient grounds for the trial court to award the outstanding medical expenses. What happened to the mother's appeal The mother had another objection. She argued that the custody proceedings should have been handled by the court that dealt with her divorce rather than a different district court in Travis County. The appeals court rejected this argument, explaining that the county's system allowed district judges to hear matters within the relevant court's jurisdiction. There was also a separate disagreement over punishment for unpaid support. The trial court had ordered two-week jail terms for certain violations, with the terms running at the same time, but had suspended imprisonment. Udall challenged that decision as well. However, the appeals court said contempt orders must be challenged through a different legal process and therefore did not decide that part of her case.