## Facts

- A 2007 parentage order named Stephanie Lee and Benjamin Jay Redus joint managing conservators and gave Lee the exclusive right to designate their child’s primary residence.
- Redus filed a suit to modify conservatorship, alleging changed circumstances, child-safety concerns, and seeking restrictions related to Lee’s husband, Scott Lee, a registered sex offender.
- Before trial, the parties, represented by counsel, executed a mediated settlement agreement (MSA) stating it was binding and not subject to revocation.
- The MSA provided that Redus would have custody, Lee would have defined possession and access, and Scott Lee would be enjoined from being within five miles of the child.
- The trial court refused to enter judgment on the MSA, stating it was not in the child’s best interest.
- Lee sought mandamus relief; the court of appeals denied relief, and Lee petitioned the Texas Supreme Court.

## Issues

1. Whether a trial court abuses its discretion by refusing to render judgment on a statutorily compliant mediated settlement agreement in a suit affecting the parent-child relationship based solely on the court’s best-interest determination.

## Decision

- The Texas Supreme Court conditionally granted mandamus relief and directed the trial court to enter judgment on the MSA.
- The Court held the trial court abused its discretion by refusing to enter judgment on a properly executed MSA on the ground that it was not in the child’s best interest.
- The Court concluded the MSA satisfied the statutory requirements of Texas Family Code § 153.0071(e), and no statutory exception authorizing refusal was applied.

## Legal Principles

- Under Tex. Fam. Code § 153.0071(e), if an MSA in a suit affecting the parent-child relationship (1) contains the required prominently displayed nonrevocation statement and (2) is signed by the parties and, if present, their attorneys, a party is entitled to judgment on the agreement “notwithstanding… another rule of law.”
- The statutory entitlement to judgment under § 153.0071(e) displaces a trial court’s free-standing authority to refuse judgment based on an independent best-interest review when the MSA meets statutory requirements.
- Any authority to deny judgment on a compliant MSA must come from a specific statutory exception; absent such an exception, the trial court must render judgment on the MSA.

## Conclusion

The Court held that when a mediated settlement agreement in a custody case complies with Texas Family Code § 153.0071(e) and no statutory exception applies, the trial court must enter judgment on the agreement and may not refuse solely because it believes the agreement is not in the child’s best interest.


In re Lee, 411 S.W.3d 445 (Tex. 2013)