Child Custody

Texas 7th Court of Appeals, Child Custody, Civil Procedure, Family Law

Bracken v. Bracken — Default Divorce Judgment Reversed Because Pro Se Party Received No Notice of Trial After Attorney Withdrew Without Following Rule 10

automatic / June 13, 2026

The Seventh Court of Appeals reversed a post-answer default judgment in a divorce case, holding that a pro se defendant received no notice of the trial setting after her attorneys withdrew without serving her by certified mail as required by Rule 10, and that subsequent electronic-only service failed to comply with the trial court’s own notice order and could not trigger the Rule 21a presumption of receipt.