The Texas Supreme Court issued an opinion in Morrison v. Morrison clarifying the boundaries between enforcement and modification of divorce decrees, holding that trial courts retain jurisdiction to enforce property divisions but cannot improperly reallocate assets without evidence of damages.

In the case styled Debbie Jo Morrison v. Rodney Wayne Morrison, Justice Bland delivered the Court's opinion addressing when divorce courts exceed their enforcement powers under the Texas Family Code. The dispute arose from a failed attempt to enforce a divorce decree's property division after one spouse allegedly failed to maintain community estate property.

The Court examined the distinction between permissible enforcement actions and prohibited modifications under Texas Family Code sections 9.001(a) and 9.007(b). The Family Code allows divorced parties to return to court seeking enforcement of their decree, but specifically prohibits orders that "amend, modify, alter, or change" the original property division. Such orders are "beyond the power of the divorce court and is unenforceable," the Court noted.

The procedural history shows the trial court initially exercised enforcement jurisdiction when Debbie Morrison sought relief after Rodney Morrison allegedly failed to maintain marital property. However, the Twelfth District Court of Appeals reversed, holding that the trial court exceeded its jurisdiction by improperly modifying the decree's property division rather than simply enforcing it. The appeals court vacated the order and dismissed the case for want of jurisdiction.

The Supreme Court's analysis focused on determining "whether the trial court properly exercised its jurisdiction to enforce a decree when one spouse failed to maintain property of the community estate." The Court emphasized that the critical distinction depends largely on the relief granted by the trial court.

Under the Family Code's enforcement provisions, courts may grant relief to redress violations of divorce decrees, including recovery of damages from a breaching spouse's assets resulting from the breach. However, the statute explicitly prohibits redividing the property itself. This creates a narrow but important distinction between compensating for harm caused by decree violations versus altering the original property allocation.

The Court established a two-part holding addressing both jurisdictional and substantive issues. First, the Supreme Court held that "the trial court had jurisdiction to enforce the decree and to award damages caused by breach of the decree." This affirms that divorce courts retain continuing jurisdiction to address violations of their decrees through appropriate remedies.

Second, the Court found that "the trial court erred in reallocating the proceeds from the sale of the marital home to the aggrieved spouse without evidence of the property damages resulting from breach of the decree." This portion of the ruling establishes that while enforcement jurisdiction exists, courts cannot simply transfer property or proceeds between former spouses without demonstrating specific damages caused by the breach.

The Court's reasoning emphasizes the importance of evidence in enforcement proceedings. While the Family Code permits damage awards to compensate for decree violations, such awards must be supported by evidence showing actual harm resulted from the breaching spouse's conduct. Courts cannot use enforcement proceedings as vehicles for essentially re-litigating property division issues or making equitable adjustments unsupported by proof of damages.

The procedural outcome reflects this nuanced approach to enforcement jurisdiction. Rather than affirming the court of appeals' dismissal for lack of jurisdiction, the Supreme Court "reverse[d] the court of appeals' judgment and remand[ed] the case to the trial court for further proceedings." This disposition preserves the trial court's jurisdiction while requiring it to properly apply the legal standards governing enforcement remedies.

The remand suggests that if Debbie Morrison can present evidence showing specific damages caused by Rodney Morrison's alleged failure to maintain the property, the trial court may have authority to award appropriate compensation. However, any such relief must be grounded in proof of actual harm rather than general notions of fairness or equity.

This decision provides important guidance for family law practitioners and divorced parties seeking to enforce property provisions in their decrees. The ruling clarifies that enforcement jurisdiction continues after divorce, but courts must carefully distinguish between permissible damage awards for proven violations and impermissible modifications of the original property division.

The Court's approach balances competing policy considerations in family law enforcement. While maintaining access to judicial remedies for decree violations, the decision prevents courts from effectively relitigating property issues under the guise of enforcement. This preserves the finality of divorce decrees while ensuring meaningful remedies remain available for actual violations.

For practitioners, the decision emphasizes the importance of developing factual records demonstrating specific damages when seeking enforcement remedies. Generic claims of property maintenance failures will likely prove insufficient without evidence connecting the alleged breach to quantifiable harm.

The case was argued before the Supreme Court on October 7, 2025, with the opinion delivered by Justice Bland. The underlying divorce proceedings and subsequent enforcement litigation originated in a Texas trial court before proceeding through the Twelfth District Court of Appeals on petition for review.