Monroe v. Monroe, 358 S.W.3d 711

Dalal and David Monroe married in 2000 and signed pre- and post-marital agreements converting substantial separate property to community property.
They separated in 2006 and divorced in 2010; no children were born of the marriage; trial court upheld the agreements.
Key community assets included Telesis Group stock valued at $4.4 million, a Mandalay Street house with about $2.4 million equity, and an antique telephone collection valued at $2.7 million.
Telesis Group held interests in E-Watch Texas, E-Watch Nevada, and Symmetrics, with significant operations attributed to David, including patents and management.
The trial court valued the net community estate at approximately $9.36 million and divided assets between Dalal and David, including a $250,000 payment to Dalal for fees and home-related obligations.
Dalal challenged several findings of fact (FFs) and the overall just-and-right division, arguing issues related to valuation and characterization of property, while the court defended its discretion under Murff factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Evidence sufficiency for FF 3 and 38A	Telesis Group formed during marriage; value derivation contested.	There is sufficient evidence the group formed from David's preexisting property; findings correct.	Findings 3 and 38A affirmed; evidence supports household integration of assets.
Value of Telesis Group without David's involvement	Telesis stock would retain value independently of David's involvement.	David materially contributes; stock would be minimally valued without him.	Finding 21 upheld; David's contributions are integral to value.
Valuation of Jaffe furniture	Purchase-price-based valuation from 1997 may overstate current value.	Dalal offered no alternative valuation method; trial court used purchase price.	Finding 25 affirmed; no remand for valuation method.
Characterization of Dalal's jewelry as community property	Jewelry was Dalal's separate property (pre-marriage or gifts).	Jewelry should be treated as community property and divided accordingly.	Jewelry deemed community property, but mischaracterization had de minimis effect; no remand.
Just and right division of the community estate	Disparities in earnings, debts, and tax liabilities justify a different split.	Trial court properly weighed Murff factors; division was just and right.	Division not an abuse of discretion; no reversal.

Murff v. Murff, 615 S.W.2d 696 (Tex. 1981) (guides evaluation of just-and-right division using Murff factors)
Garza v. Garza, 217 S.W.3d 538 (Tex.App.-San Antonio 2006) (sufficiency standard in evaluating division of community estate)
In re An Unborn Child, 153 S.W.3d 559 (Tex.App.-Amarillo 2004) (designation of findings of fact vs conclusions of law not controlling on appeal)
Grossnickle v. Grossnickle, 935 S.W.2d 830 (Tex.App.-Texarkana 1996) (remand not required for de minimis mischaracterization of property)
Vannerson v. Vannerson, 857 S.W.2d 659 (Tex.App.-Houston [1st Dist.] 1993) (absence of alternative valuation method weakens error claim)
Pace v. Pace, 160 S.W.3d 706 (Tex.App.-Dallas 2005) (clear-and-convincing standard for spouse's separate-property assertions)
Horlock v. Horlock, 533 S.W.2d 52 (Tex.Civ.App.-Houston [14th Dist.] 1975) (noting genesis of community estate may be considered)
Zorilla v. Wahid, 83 S.W.3d 247 (Tex.App.-Corpus Christi 2002) (consideration of spouse contributions to finances)
Moroch v. Collins, 174 S.W.3d 849 (Tex.App.-Dallas 2005) (nonexclusive factors for division of property)
Iliff v. Iliff, 339 S.W.3d 74 (Tex. 2011) (contextual post-analytic discussion on interrelationships of contributions)