McCollough v. McCollough
Randy McCollough appealed a partial summary judgment granted to his ex-wife, Cherie McCollough, regarding the modification of alimony payments. Randy sought to modify his contractual alimony obligations, based on an alleged informal marriage by Cherie, by invoking provisions of Chapter 8 of the Texas Family Code, which governs spousal maintenance. Cherie argued that their agreement incident to divorce, which established the alimony, was a contract governed by contract law and not subject to modification under Chapter 8. The appellate court affirmed the district court's summary judgment, holding that the contractual alimony agreement between Randy and Cherie was governed by contract law and not the termination and modification provisions of Chapter 8 of the Family Code. The court emphasized the historical distinction between court-ordered alimony and contractual alimony in Texas law and found that the parties' agreement intended to create a contractual obligation outside of Chapter 8's strict limitations.