Supreme Court

Mehta v. Mehta

• Case number: 23-0507
• Legal category: Family Law
• Subtype: Spousal Support
• Set for oral argument: February 18, 2024

Case Summary

The principal issue in this case is whether child-support payments should be considered when determining a spouse’s eligibility for spousal maintenance.

Manish Mehta filed for divorce from his spouse, Hannah Mehta. In the final divorce decree, the trial court ordered Manish to pay child support and spousal maintenance to Hannah. Manish appealed, arguing that the evidence is legally insufficient to support the spousal maintenance award under Chapter 8 of the Texas Family Code.

The Family Code allows the trial court to award spousal maintenance when the spouse seeking maintenance will lack sufficient property upon divorce to provide for their minimum reasonable needs. In its review, the court of appeals included Manish’s child support payments as part of the property available to provide for Hannah’s minimum reasonable needs. It then reviewed evidence of Hannah’s minimum reasonable needs. After comparing the two, the court reversed the award of spousal maintenance, holding that Hannah is ineligible for spousal maintenance because she has sufficient property to provide for her needs.

Hannah filed a petition for review. She argues that the court of appeals erred because spousal maintenance is intended to provide only for the spouse’s needs, while the purpose of child support is to financially support the children. Accordingly, Hannah argues that receipt of child support should not be considered when determining a spouse’s eligibility for spousal maintenance. The Supreme Court granted the petition.

Case summaries are created by the Court's staff attorneys and law clerks and do not constitute the Court’s official descriptions or statements. Readers are encouraged to review the Court’s official opinions for specifics regarding each case.