in the Matter of the Marriage of Wilma McCoy and Charles E. McCoy, 567 S.W.3d 426

Wilma and Charles McCoy married in December 2000, separated October 2015; no children. Wilma filed for divorce about a year after separation; Charles was served but did not appear.
Trial court granted the divorce after a short hearing and awarded Wilma the family home (9 acres), various retirement assets, a 1993 Peterbilt truck, a 2008 Chevrolet pickup, and ordered Charles to pay spousal maintenance of $500/month for up to five years.
Wilma was the sole witness at the hearing. She testified she receives $800/month Social Security and $300–$500/month from sporadic work; she stated she needed at least $500/month to pay expenses.
Wilma offered no evidence of specific job skills, efforts to obtain more work, efforts to develop employment skills, or any physical/other limitations affecting employability.
Trial court awarded spousal maintenance under Texas Family Code §8.051(2)(B); on appeal Charles argued the maintenance award was unsupported because Wilma failed to rebut the statutory presumption against maintenance.

Issue	Wilma's Argument	Charles' Argument	Held
Whether evidence rebutted presumption that maintenance is not warranted under Tex. Fam. Code §8.053 when seeking §8.051(2)(B) maintenance	Wilma argued her testimony about Social Security and sporadic work was sufficient to show diligence and need	Charles argued there was no evidence of diligence in earning income or developing skills to meet minimum reasonable needs	Reversed: Wilma failed to overcome the presumption; evidence legally insufficient to support maintenance award
Whether trial court abused discretion in awarding spousal maintenance	Wilma contended judge acted within discretion based on her testimony of need and fault	Charles argued lack of substantive and probative evidence rendered the award an abuse of discretion	Court held abuse of discretion because no substantive evidence to support award
Whether legal sufficiency standard satisfied for vital facts (diligence and skill development)	Wilma relied on her limited earnings and Social Security as proof	Charles asserted a no-evidence challenge: complete absence or less-than-scintilla of proof on diligence/skill development	Court found less-than-scintilla/complete absence of evidence and sustained the no-evidence complaint
Scope/other statutory challenges (duration/amount)	Wilma did not separately defend on appeal	Charles raised additional points about perpetuity and statutory maximum	Court did not reach remaining issues because reversal on presumption ground was dispositive

Jelinek v. Casas, 328 S.W.3d 526 (Tex. 2010) (legal-sufficiency/no-evidence framework)
King Ranch, Inc. v. Chapman, 118 S.W.3d 742 (Tex. 2003) (definition of less-than-a-scintilla evidence)
Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238 (Tex. 1985) (abuse-of-discretion standard)
Sheshtawy v. Sheshtawy, 150 S.W.3d 772 (Tex. App.—San Antonio 2004) (presumption against maintenance not overcome with similar testimony)
Deltuva v. Deltuva, 113 S.W.3d 882 (Tex. App.—Dallas 2003) (purpose and limits of spousal maintenance)