In the Interest of M.A.H., 365 S.W.3d 814

Appellant (mother) and appellee (father) are the parents of three minor children and seek a divorce plus a suit affecting the parent-child relationship.
The parties negotiated a Rule 11 agreement on property division, spousal maintenance, and conservatorship/child-related provisions without attorneys.
Appellee’s attorney prepared a written Rule 11 agreement incorporating an unequal property division in appellee’s favor, joint managing conservatorship, residence designation, child support, and spousal maintenance.
The agreement stated in capitalized terms that it was not subject to revocation and acknowledged the parties read and understood it and could seek counsel.
Appellant signed the agreement on July 16, 2010, later claimed she signed under duress and without opportunity to review; she moved to set aside the agreement after retaining counsel.
The trial court entered a final judgment on August 12, 2010, consistent with the Rule 11 agreement, and later denied a motion for new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can a judgment enforcing a Rule 11 agreement be entered after revocation of consent?	Appellant revoked consent; enforcement should not proceed.	Rules allow enforcement if the agreement is binding under § 6.604 and the court finds it just and right.	Enforcement of child-related provisions void; divorce and property issues may be remanded for reconsideration.
Effect of revocation on child support, conservatorship, and possession orders	Revocation invalidates orders based on the agreement.	Court may enforce those terms if binding, independent of revocation.	Court could not enter orders on child support, conservatorship, or possession based solely on the revoked agreement.
Does estoppel by acceptance of benefits bar appellant’s appeal?	Appellant accepted benefits; estoppel applies.	Economic necessity can negate voluntary acceptance; estoppel not proven here.	Appellee failed to prove estoppel due to appellant’s economic necessity.
Remedy for dissolution of marriage and property division after revocation	Court should enforce the property division as agreed or set for contested proceedings.	If not just and right, parties may submit revised terms or have a contested hearing.	Remand for reconsideration of property division; if not just and right, revised agreement or contested hearing required.

Ford Motor Co. v. Castillo, 279 S.W.3d 656 (Tex. 2009) (revocation defeats agreed judgment; separate breach action permissible)
Padilla v. LaFrance, 907 S.W.2d 454 (Tex. 1995) (breach of contract enforcement via separate claim when consent revoked)
Gunter v. Empire Pipeline Corp., 310 S.W.3d 19 (Tex. App.-Dallas 2009) (revocation of agreement and enforcement standards)
S & A Restaurant Corp. v. Leal, 892 S.W.2d 855 (Tex. 1995) (voidness when one party revokes an agreed settlement)
Milner v. Milner, 361 S.W.3d 615 (Tex. 2012) (mediated settlement irrevocability; distinction from unmediated agreements)
Jensen v. Jensen, 665 S.W.2d 107 (Tex. 1984) (ends of justice may warrant remand to determine just and right division)