Avelardo Miranda v. Maria T. Miranda
Avelardo and Maria Miranda divorced in 1974. In 1978, Maria obtained a default judgment in Texas for a division of military retirement benefits and child support from Avelardo. In 2006, Maria filed a motion to change the method of payment of Avelardo's military retirement benefits, which the trial court granted, holding it had the power to modify the 1978 order nunc pro tunc. On appeal, Avelardo contended the trial court lacked plenary power and improperly modified the judgment. The appellate court concluded that the trial court's modification was a judicial error, not a clerical one, and that the trial court lacked jurisdiction to revise the 1978 judgment after its plenary power expired. Therefore, the judgment of the trial court was reversed and rendered in favor of Avelardo Miranda.