Here’s a case that confirms the general proposition that child support judgments never go away.

The Dallas Court of Appeals ruled in In re S.H., No. 05-17-00336-CV, 2018 WL 3751297 (Tex. App.—Dallas 2018, no pet. h.) (mem. op.) (08-08-18), that a final decree ordering Father to pay child support until the Child was 18 was exempt from revival of judgment rules.   The facts were that the Father never paid any child support. Ten years after the order, Mother filed a motion for enforcement. After a trial, the court found it lacked authority to hold Father in contempt but retained authority to enter a judgment for unpaid support. After the entry of an order confirming Father’s arrearages and awarding Mother her attorney’s fees, Father appealed. He argued that the decree Mother sought to enforce was a “dormant” order, and Mother did not plead for a revival of the judgment. The Court held that while the Civil Practices and Remedy Code provides that a judgment is dormant, and execution may not issue when a judgment is greater than ten years old, the legislature has explicitly excluded child support from the dormancy statue.