in Re: E. B., 12-17-00214-CV

Divorcing couple E.B. and M.B. entered a Rule 11/Informal Settlement Conference in a Smith County divorce suit with preservation of parental rights and finances; the written Agreement stated it was not subject to revocation once filed with the court.
The Agreement addressed joint conservatorship, primary residence designations, child support, education decisions, and related terms, along with ancillary provisions for spousal support and attorney/amicus fees.
The Agreement was signed by both parties and their attorneys and stated not subject to revocation; it was framed as the result of an informal settlement conference under Texas Family Code §6.604.
E.B. later petitioned to modify the Agreement as circumstances changed; he formally revoked his consent on April 25, 2017.
The trial court denied revocation, entered temporary orders reflecting the Agreement, and the mandamus petition followed seeking relief on the child-related provisions.
The court ultimately held the Agreement was not a mediated settlement under §153.0071 but satisfied §6.604 for dissolution issues, allowing voiding of child provisions while upholding dissolution provisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Rule 11/6.604 agreement is a mediated settlement requiring irrevocability	E.B. contends the agreement was a mediated settlement	M.B. contends the agreement is a mediated settlement under §153.0071 and irrevocable	Not a mediated settlement; revocation allowed before judgment
Whether the agreement met §6.604 requirements to yield judgment on dissolution issues	N/A	M.B. argues for judgment on dissolution terms	Agreement satisfied §6.604 for dissolution provisions; trial court could grant judgment on those terms
Whether E.B. is estopped from challenging the agreement under acceptance-of-benefits	M.B. argues benefits bar challenge	N.B. contends unbiased estoppel and prejudice considerations apply	Not estopped; any prejudice to M.B. is curable

Proffer v. Yates, 734 S.W.2d 671 (Tex. 1987) (mandamus when ordinary remedies inadequate)
In re Knotts, 62 S.W.3d 922 (Tex. App.—Texarkana 2001) (mandamus under family-law context)
In re Derzapf, 219 S.W.3d 327 (Tex. 2007) (temporary orders abuse standard in SAPCR)
In re Green, 385 S.W.3d 665 (Tex. App.—San Antonio 2012) (mandamus and temporary-order review in family law)
ExxonMobil Corp. v. Valence Operating Co., 174 S.W.3d 303 (Tex. App.—Houston [1st Dist.] 2005) (consent to judgment and revocation timing)
Leal, 892 S.W.2d 857 (Tex. 1995) (cannot sanction an agreed judgment absent consent)
Lee v. Lee, 158 S.W.3d 612 (Tex. App.—Fort Worth 2005) (mediator definition and role distinctions)
In re M.A.H., 365 S.W.3d 814 (Tex. App.—Dallas 2012) (unmediated child-related agreements lack irrevocability language)
Kramer v. Kastleman, 508 S.W.3d 211 (Tex. 2017) (acceptance-of-benefits doctrine analysis and prejudice factors)
In re Marriage of Stein, 153 S.W.3d 485 (Tex. App.—Amarillo 2004) (single incident can establish family-violence history)
Stallworth v. Stallworth, 201 S.W.3d 338 (Tex. App.—Dallas 2006) (family-violence considerations in conservatorship)
Quintero v. Jim Walter Homes, Inc., 654 S.W.2d 442 (Tex. 1983) (judgment validity where consent exists)