Lowe v. Lowe
Kerri Lowe appeals a default judgment in a divorce case from July 1996, where Jerome Jason Lowe was granted sole managing conservatorship of their children, child support, and a division of the marital estate. Mrs. Lowe's attorney, Greg Donnell, failed to appear for trial, having allegedly misled her about a continuance. The trial court denied Mrs. Lowe's motion for a new trial. The appellate court, applying the three-prong Craddock test for new trials after default judgments, found that Mrs. Lowe met all requirements: her failure to appear was due to an accident or mistake (her lawyer's misrepresentation), she presented a meritorious defense regarding child custody, and a new trial would not unduly delay or prejudice Mr. Lowe. Consequently, the court reversed the default judgment and remanded the case for a new trial. The opinion also critically discusses the appropriateness of the Craddock test in suits affecting the parent-child relationship.