Cline v. Cline, 557 S.W.3d 810

Jason and Adelina Cline divorced in 2012; Adelina was ordered to pay $195.33/month child support and $133.00/month medical support.
Adelina fell behind; parties entered a Rule 11 Agreement in April 2013 resolving earlier enforcement claims and specifying allocation of a $3,842.00 balance among child support, medical support, attorney fees, and other debts.
Adelina paid $4,019.96 into the court registry in 2013 (the $3,842 plus $177.96) and the funds were disbursed to Jason; records show a $1,319 credit applied August 15, 2013.
Jason filed a motion to enforce in 2017; the trial court entered a judgment finding Adelina $519.50 in child support arrears and $3,469.75 in medical-support arrears and adjudicated her criminally contemptuous on four counts, ordering 180 days’ jail on each count to run concurrently.
On appeal, the appellate court addressed (1) whether it had jurisdiction to review the contempt adjudication and (2) whether the arrearage judgment correctly accounted for the 2013 payment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to review contempt adjudication	Adelina argues the contempt findings were erroneous because her inability-to-pay defense was uncontroverted.	Trial court and State: contempt orders are not appealable; must be attacked by habeas or mandamus.	Dismissed for lack of jurisdiction; contempt claims must be pursued by original proceeding.
Application of 2013 payment to arrearages	Adelina contends the entire $4,019.96 paid through the disbursement unit should have been applied first to child support under Fam. Code §157.268, eliminating her arrears.	Jason and trial court: Rule 11 Agreement expressly allocated the payment among multiple debts; at time of payment child/medical support owed was only $690/$452 so excess properly applied to other agreed debts.	Affirmed: trial court had sufficient evidence and did not abuse discretion in refusing further credits under the Rule 11 Agreement.

Cadle Co. v. Lobingier, 50 S.W.3d 662 (Tex. App.-Fort Worth 2001) (contempt judgments reviewable only by habeas or mandamus).
In re Long, 984 S.W.2d 623 (Tex. 1999) (discussing limits on appellate review of contempt).
Worford v. Stamper, 801 S.W.2d 108 (Tex. 1990) (standard of review for arrearage confirmation: abuse of discretion).
In re Dep't of Family & Protective Servs., 273 S.W.3d 637 (Tex. 2009) (party cannot request specific action and later complain on appeal).
Metzger v. Sebek, 892 S.W.2d 20 (Tex. App.-Houston [1st Dist.] 1994) (contempt orders not appealable when appealed with an otherwise appealable judgment).
Norman v. Norman, 692 S.W.2d 655 (Tex. 1985) (historical treatment of contempt jurisdiction in family-code context).