When navigating a complex divorce in Dallas, understanding how Texas courts approach spousal maintenance can mean the difference between financial security and hardship. The recent Texas Court of Appeals decision in Harwood v. Harwood provides crucial insights into how courts determine spousal support eligibility and amounts, particularly when one spouse has a disability and the other claims reduced income.
This case, decided in August 2025, offers valuable lessons for Dallas-area couples facing similar circumstances. The ruling clarifies important boundaries around how courts can calculate spousal maintenance, while reaffirming protections for spouses with incapacitating disabilities. For anyone considering divorce in the Dallas metro area, this decision highlights why having an experienced dallas divorce attorney is essential when spousal support is at stake.
The Harwood decision demonstrates how even well-intentioned trial court findings can be overturned when they exceed statutory limits, emphasizing the importance of understanding both the eligibility requirements and calculation methods for spousal maintenance under Texas law.
Case Background: A 20-Year Marriage Ends in Complex Financial Dispute
Per the published case, Quinn and Kimberley Harwood’s 20-year marriage ended in 2019 when Quinn filed for divorce on grounds of insupportability. Their case involved three children between ages 16-21 and centered on Kimberley’s request for indefinite spousal maintenance due to her medical condition.
Kimberley suffers from secondary lymphedema, a chronic condition affecting both legs that causes severe swelling, pain, and mobility limitations. Her right leg retains 20-30 pounds of fluid, while her left leg has recently begun showing similar symptoms. The condition requires daily management through compression stockings, salt baths, and frequent leg elevation, and has resulted in multiple hospitalizations for infections.
Due to her lymphedema, Kimberley has received Social Security disability payments since 2003, totaling $1,900 monthly at the time of trial. She last worked from 1999-2002 at Chanel in Los Angeles, supporting the family during Quinn’s periods of unemployment following his brief professional basketball career.
Quinn’s employment history proved equally complex. After playing professional basketball from 1998-1999, he worked intermittently at 24 Hour Fitness from 2001-2020, with periods of unemployment in between. His income peaked in 2019 at $141,918 gross pay before being furloughed during COVID-19. Since 2021, he’s worked as a self-employed life coach earning approximately $3,300 monthly.
The financial stakes were significant. Kimberley presented a monthly budget showing $6,172 in income against $9,956 in expenses for herself and the children. She requested spousal maintenance equal to 20% of Quinn’s gross income for an indefinite period, arguing her disability prevented full-time employment.
Legal Analysis: When Courts Can and Cannot Impute Income for Spousal Support
The Williamson County trial court made two critical findings that shaped this appeal. First, it determined Kimberley qualified for spousal maintenance under Texas Family Code Section 8.051(2)(A) due to her incapacitating physical disability. Second, it found Quinn was “intentionally underemployed” and calculated spousal support based on deemed earnings of $120,000 annually rather than his actual $39,600 income.
Spousal Maintenance Eligibility: A Sound Foundation
The Court of Appeals affirmed the trial court’s eligibility determination, finding substantial evidence supported Kimberley’s qualification for spousal maintenance. Under Section 8.051(2)(A), a spouse is eligible when they cannot earn sufficient income due to an “incapacitating physical or mental disability.”
The evidence clearly established Kimberley’s lymphedema as incapacitating. Medical testimony showed the condition causes constant pain, severely limits mobility, and requires extensive daily care. When Kimberley overexerts herself, she becomes “debilitated” and needs three to four days of bed rest to recover. The court noted her 20-year absence from the workforce and testimony from family members about the condition’s severity.
Importantly, this finding allowed for indefinite spousal maintenance duration under Section 8.054(b), as long as Kimberley continues meeting the eligibility criteria. This provides crucial long-term financial security for spouses with permanent disabilities, a best practice that experienced Dallas divorce lawyers understand when advocating for disabled clients.
The Fatal Flaw: Exceeding Statutory Limits on Spousal Support Calculation
While affirming eligibility, the Court of Appeals reversed the $1,500 monthly award amount, finding the trial court exceeded its statutory authority. This reversal centered on a fundamental distinction between child support and spousal maintenance calculations under Texas law.
For child support, Section 154.066(a) explicitly allows courts to impute income based on “earning potential” when a parent is intentionally underemployed. However, no equivalent provision exists in Chapter 8 governing spousal maintenance. Section 8.055 caps spousal maintenance at the lesser of $5,000 or 20% of the obligor spouse’s “average monthly gross income” – a term defined to include only income “actually being received.”
The trial court’s error was applying child support methodology to spousal maintenance. By deeming Quinn capable of earning $120,000 annually and calculating support accordingly, the court exceeded the 20% limit based on his actual $3,300 monthly income. Twenty percent of Quinn’s actual income would yield only $660 monthly – less than half the awarded amount.
This distinction reflects different policy goals between child support and spousal maintenance. As a dallas family law attorney who handles these cases, child support prioritizes the child’s best interests and may justify income imputation, while spousal maintenance focuses on the actual financial capacity of the paying spouse.
Precedential Impact: Clarifying Limits on Judicial Discretion
The Harwood decision reinforces the holding in In re Marriage of Contreras, establishing that Texas courts cannot impute income for spousal maintenance calculations based on “intentional underemployment.” This creates important predictability for divorce planning and settlement negotiations.
The ruling also demonstrates how appellate courts will scrutinize trial court calculations that exceed statutory limits, even when the underlying eligibility findings are sound. This emphasizes the importance of precise legal advocacy in contested divorce in dallas cases involving spousal support.
Key Takeaways: What This Means for Dallas Divorcing Couples
The Harwood decision provides several crucial insights for Dallas-area couples navigating divorce with spousal maintenance issues.
Disability-Based Spousal Support Remains Protected
For spouses with genuine incapacitating disabilities, the ruling confirms strong protections under Texas law. Courts can award indefinite spousal maintenance when medical evidence clearly establishes the disability prevents substantial employment. This provides security for spouses who sacrificed career development due to health conditions during marriage.
The case also clarifies that disability need not be total incapacitation. Kimberley could perform some activities like driving children to events or occasional skiing, but the totality of evidence showed her lymphedema prevented consistent employment. This nuanced approach protects spouses whose disabilities fluctuate or allow limited activity.
Income Calculation Rules Are Strictly Applied
The reversal demonstrates that spousal maintenance calculations must strictly comply with statutory formulas. Unlike child support, courts cannot speculate about earning potential or impute income based on past employment capacity. This provides clarity for settlement negotiations and removes uncertainty about calculation methods.
For higher-earning spouses concerned about excessive support awards, the decision confirms that actual income – not potential income – governs spousal maintenance calculations. However, this same rule protects lower-earning spouses from having support calculated based on unrealistic income expectations.
Evidence Quality Determines Outcomes
The case reinforces how crucial thorough evidence presentation is in spousal maintenance cases. Kimberley’s success in establishing eligibility resulted from comprehensive medical testimony, family witness accounts, and detailed financial documentation. Her itemized budget showing the gap between income and reasonable expenses provided the foundation for the court’s eligibility finding.
Strategic Insights: How Experienced Representation Could Have Prevented This Appeal
The Harwood case illustrates several strategic considerations that experienced Dallas divorce counsel would have addressed differently, potentially avoiding the need for appeal and remand.
Proper Legal Theory Selection
An experienced dallas divorce lawyer consultation would have recognized the statutory limitations on spousal maintenance calculations from the outset. Rather than arguing for deemed income based on intentional underemployment, skilled counsel might have pursued alternative strategies such as:
- Seeking temporary spousal support during Quinn’s job search period
- Arguing for the maximum amount based on actual income with periodic review provisions
- Exploring whether Quinn’s consulting income might increase over time with proper evidence
- Considering lump-sum spousal maintenance if other assets were available
Evidence Strategy and Presentation
While Kimberley’s disability evidence was compelling, Quinn’s income evidence could have been better developed. The trial court’s finding of intentional underemployment suggests Quinn’s testimony about his job search efforts and market conditions in the fitness industry post-COVID may have been inadequate.
A strategic approach would have included:
- Expert testimony on employment opportunities in Quinn’s field
- Documentation of job search efforts and market conditions
- Evidence of any licensing or certification requirements limiting opportunities
- Clear presentation of the distinction between voluntary career change and intentional underemployment
Settlement Negotiation Opportunities
The case facts suggest missed opportunities for negotiated resolution. With Kimberley clearly eligible for some spousal support and Quinn’s income limitations apparent, counsel might have achieved a sustainable agreement avoiding the uncertainty and expense of appeal.
Successful dallas child custody lawyer and family law practitioners understand that spousal maintenance cases often benefit from creative settlement structures addressing both parties’ long-term needs rather than rigid application of statutory maximums.
Moving Forward: Protecting Your Interests in Dallas Divorce Cases
The Harwood decision underscores why spousal maintenance cases require careful legal analysis and strategic advocacy. Whether you’re seeking spousal support due to disability or other circumstances, or defending against excessive maintenance claims, understanding the precise statutory requirements is essential.
For Dallas-area residents facing similar situations, several key principles emerge from this case. First, gather comprehensive medical and financial evidence early in the process. Second, understand both the eligibility requirements and calculation limitations under Texas law. Third, consider how changing circumstances might affect long-term maintenance obligations.
The case also highlights the value of experienced local counsel familiar with Dallas family courts and Texas appellate precedent. While the Harwood couple ultimately received a fair result – with Kimberley’s eligibility affirmed and the excessive award corrected – the process required years of litigation and substantial legal costs that might have been avoided with different strategic approaches.
If you’re facing divorce in Dallas, Richardson, Irving, Garland, Mesquite, or surrounding areas, don’t navigate these complex waters alone. The stakes are too high, and the law too nuanced, to risk inadequate representation. Contact our office today to discuss your specific situation and learn how we can protect your interests while working toward a resolution that serves your family’s long-term needs.
Our 25+ years of Dallas family law experience includes successful representation in complex spousal maintenance cases, and we’re committed to providing honest assessments and strategic advocacy tailored to your unique circumstances. Call today for a consultation to discuss how we can help you achieve the best possible outcome in your divorce case.
