pjc-family-2024-lib

F RAUD —D ISSOLUTION OF M ARRIAGE

PJC 206.3

Other actual fraud theories. The foregoing submission reflects only one of many theories of actual fraud that might be presented in a case involving spouses. See, e.g., Stone v. Lawyers Title Insurance Corp. , 554 S.W.2d 183 (Tex. 1977); Uniform Fraudulent Transfer Act, Tex. Bus. & Com. Code §§ 24.001–.013. The variety of pos sible theories is too great to be comprehensively covered in this book, but the submis sion may be altered to present other theories. See, e.g., Cantu v. Cantu , 556 S.W.3d 420, 426 (Tex. App.—Houston [14th Dist.] 2018, no pet.); Logsdon v. Logsdon , No. 02-14-00045-CV, 2015 WL 7690034 (Tex. App.—Fort Worth Nov. 25, 2015, no pet.) (mem. op.). Include this additional instruction. The instruction in PJC 206.1 (confidence and trust relationship between spouses) should be given with the foregoing instruction and questions.

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