Case Alert: Prasad Puligundla v. Leela Madipuri (Houston - 2025)
By May 2, 2025 Posted in News Tagged in Child Custody Share
Factual and Procedural Background
The case Prasad Puligundla v. Leela Madipuri involves a contentious divorce between Prasad Puligundla and Leela Madipuri, both originally from India, who settled in Brenham, Texas. Prasad moved to the United States and began working for Germania in Brenham in October 2000. His parents arranged his marriage to Leela, whom he met and married in India in 2004. After their wedding, the couple returned to Brenham and started a family, having two sons: Bihma, born in 2007, and Arunja, born in 2010. Bihma is described as academically gifted with a good sense of humor, while Arunja, who has cerebral palsy, has adapted to his condition through therapy, showing determination by refusing most school accommodations.
The marriage deteriorated, and on October 29, 2018, Prasad filed for divorce, citing Leela’s adultery as the grounds after discovering her affair with his friend Bhoja in India. Prasad sought to be appointed the joint managing conservator with the exclusive right to designate the children’s primary residence, make educational and health decisions, and receive child support from Leela. He also requested 100% of the marital residence. Leela filed a counterpetition, alleging cruelty by Prasad and claiming that both parties had committed fraud against each other’s community property rights.
The case was heard by a Washington County jury over eight days, from August 12 to August 22, 2022. The parties agreed to a joint managing conservatorship and that the children’s primary residence would remain in Washington County, but they disputed who would have the exclusive right to designate the primary residence. The jury found that Leela had committed adultery but rejected her claim of cruelty by Prasad. It also determined that both parties had committed fraud on the community estate: Leela depleted the estate by $9,300 sent to Bhoja, and Prasad depleted it by $69,500 wired to his father after filing for divorce. The jury awarded Prasad the exclusive right to designate the children’s primary residence.
On August 15, 2023, the trial court issued its Final Divorce Decree, affirming Prasad’s right to designate the children’s primary residence within Washington County. Both parents were ordered to pay child support, but after offsets, Prasad was required to pay Leela $1,660 monthly. The court ordered a 50/50 possession schedule, alternating weekly from Friday to Friday, and awarded the marital residence to Leela. Prasad filed a motion for a new trial, a notice of appeal, and a request for findings of fact and conclusions of law, which the trial court issued belatedly on November 7, 2023.
Issues on Appeal
Prasad appealed the trial court’s decree to the Court of Appeals, raising three issues: (1) whether the 50/50 possession schedule violated Texas Family Code § 105.002 by undermining his exclusive right to designate the children’s primary residence; (2) whether the possession schedule was supported by legally and factually sufficient evidence to be in the children’s best interests; and (3) whether the division of the community estate was just and equitable, given what he claimed was a disproportionate award to Leela.
Appellate Court’s Analysis and Decision
Issue 1: Legality of the 50/50 Possession Schedule
Prasad argued that the trial court’s week-on/week-off possession schedule contravened the jury’s finding that he should have the exclusive right to designate the children’s primary residence, citing Texas Family Code § 105.002. He urged the court to adopt the reasoning of the Corpus Christi and San Antonio Courts of Appeals, which held that a 50/50 possession schedule effectively creates two primary residences, nullifying the jury’s designation. He contended that the schedule rendered his “exclusive right” meaningless, as it implied the children had two primary homes.
The appellate court, reviewing the issue de novo, interpreted § 105.002 by focusing on its plain language. Section 105.002(c)(1)(D) allows a jury to determine which joint managing conservator has the exclusive right to designate the child’s primary residence, while § 105.002(c)(2)(B) prohibits submitting specific possession terms to the jury, leaving those to the court’s discretion. The court defined “primary residence” as the legally recognized principal home, determined by the designated parent, not by possession time. It rejected Prasad’s argument, aligning with the Dallas Court of Appeals in In Interest of W.B.B. (2018), which held that equal possession time does not conflict with the right to designate primary residence. The court noted that primary residence is significant for school enrollment and relocation decisions, not possession time. Since both parents lived close to each other in Washington County, the 50/50 schedule did not undermine Prasad’s right. The court overruled this issue, finding no violation of the Family Code.
Issue 2: Best Interests of the Children
Prasad’s second issue challenged the possession schedule as an abuse of discretion, arguing it lacked legally and factually sufficient evidence to support that it was in the children’s best interests. The court applied an abuse-of-discretion standard, under which legal and factual sufficiency are factors. It reviewed the record for evidence supporting the trial court’s decision, considering the Holley factors for determining a child’s best interests, such as the children’s needs, parental abilities, and home stability.
The trial court’s findings highlighted Leela’s role as the primary caregiver before the divorce, managing the children’s daily needs, education, and activities, including Arunja’s therapy for cerebral palsy. Witnesses, including a neighbor, an occupational therapist, and a therapy coordinator, testified that Leela was actively involved in the children’s lives, particularly in Arunja’s therapy, while Prasad’s involvement increased only after filing for divorce. Evidence showed Prasad often dropped Arunja off at therapy without participating, sometimes arriving late to pick him up, and that Arunja appeared more stressed when with Prasad. Bihma also preferred bathing at Leela’s home, indicating comfort there. While Prasad presented witnesses praising his parenting, the court found Leela’s evidence more compelling, showing her consistent care, especially for Arunja’s special needs. The court concluded that the record supported the 50/50 schedule as being in the children’s best interests, with no abuse of discretion, and overruled this issue.
Issue 3: Division of the Community Estate
Prasad’s final issue contested the division of the community estate, arguing that the trial court awarded Leela a disproportionate share (52.66% to her, 47.34% to him, or $690,802.04 to Leela and $621,129.94 to Prasad, excluding a 50/50 split Germania Pension Plan). He claimed the division was not just and right under Texas Family Code § 7.001 and the Murff factors, which consider earning capacity, fault, and financial needs.
The court reviewed the division for abuse of discretion, ensuring the trial court had sufficient information and the division was not manifestly unjust. The trial court’s findings noted Prasad’s concealment of a retirement account and his greater earning capacity, as he worked at Germania throughout the marriage, while Leela, despite a computer science degree, had not worked for most of the marriage to care for the children. The court acknowledged Leela’s adultery but noted that fault is not mandatory in property division and should not be used to punish a spouse. Given the slight disparity in the division and Leela’s lower earning potential, the court found the division equitable and not an abuse of discretion, overruling this issue.
Conclusion
The Court of Appeals affirmed the trial court’s Final Divorce Decree on April 29, 2025, finding no legal impediment to the 50/50 possession schedule, sufficient evidence that it was in the children’s best interests, and an equitable division of the community estate. The decision balanced the children’s need for stability with both parents’ involvement, while ensuring a fair property division despite the marital fault.