The Texas Supreme Court’s June 2025 decision in Mehta v. Mehta (No. 23-0507) is a game-changer for family lawyers and mediators. It grounds spousal maintenance in real-world family realities, not just in spreadsheets. If you’re navigating support for a stay-at-home caregiver or challenging maintenance claims, this case is your new toolkit essential. The Court didn’t rewrite Texas Family Code § 8.051—it clarified it with a fair outcome based on common sense, continuing Texas’s evolving trend of tying maintenance to actual family dynamics.
The Facts: What Happened in Mehta
Hannah and Manish Mehta married in 2000 and had triplets in 2007, one of whom is medically fragile and requires around-the-clock care. Hannah left the workforce to become their full-time caregiver and later secured a modestly paid job with a nonprofit she co-founded.
The trial court awarded her $2,000/month in spousal maintenance and $2,760/month in child support. The Court of appeals reversed the maintenance award, holding that she failed to present sufficient itemized proof of need.
The Texas Supreme Court unanimously reversed that decision, reinstating the post-divorce spousal maintenance award. Justice Huddle’s majority opinion, bolstered by Justice Lehrmann’s practical concurrence (joined by Justice Busby), emphasizes context over rigid formulas.
Key Takeaway #1: Spreadsheets Are Optional, Reality Is Required
Itemized financial statements and spreadsheets are helpful. But they aren’t mandatory.
The Court held that qualitative evidence—like testimony about unpaid bills, caregiving responsibilities, and difficulty meeting basic expenses—can suffice under Texas Family Code § 8.051.
In other words, your client’s story matters. Courts can (and should) rely on what makes sense in context. That includes common-sense observations about what it costs to keep the lights on, get to therapy appointments, and provide care for a disabled child.
Practice Tip: Come to mediation with more than a ledger. Bring your client’s narrative. What’s their life actually like? Why can’t they work more—or at all? What unique child-related expenses do they have to provide? After Mehta, the answers to those questions matter more than ever.
Key Takeaway #2: Child Support Isn’t Free Income
The appellate Court in Mehta made a crucial error. It treated child support as a fully available asset for a parents’ personal needs, ignoring the child-related expenses that child support is intended to cover.
The Supreme Court corrected this. If child support is counted as income, then the related expenses must also be counted. Otherwise, you’re “double-counting”—a budgeting fiction that punishes caregivers.
Example from Mehta: Hannah’s combined mortgage and property taxes were $2,788/month. Her $2,760 in child support didn’t even cover that. Pretending the child support was extra cash distorted the financial reality of her minimum reasonable needs.
Practice Tip: When child support is in play, break down actual child-related costs. If you’re negotiating maintenance, don’t let child support be treated as a personal subsidy. And if you’re opposing it, come with evidence that the child support exceeds the child’s actual needs.
Key Takeaway #3: Caregiving for a Disabled Child Is Its Own Ground for Maintenance
Mehta reaffirmed a powerful but often overlooked provision. Texas Family Code § 8.051(2)(C) allows spousal maintenance when a parent is the custodian of a disabled child and can’t work as a result.
No rebuttable presumption against maintenance applies. No need to prove job-hunting or retraining. If the child’s needs prevent employment, that’s enough!
In Mehta, evidence of daily IV infusions, feeding tube care, and medical travel to Boston was deemed more than sufficient.
Practice Tip: If your client is a caregiver, document the load. Use therapy schedules, doctor’s notes, and even travel logs to illustrate the time commitment. If you’re on the other side, examine whether part-time or remote work is realistic—but don’t assume.
Justice Lehrmann’s Concurrence: Use A Little Math
Justice Lehrmann’s concurring opinion distilled the case well: focus on the whole financial picture, not dissected pieces.
She offered a helpful hypothetical—if someone has $4,000 in income (including child support) but $5,000 in combined expenses, there’s a shortfall. Whether that money goes to groceries, rent, or tutoring isn’t the point. The point is need.
Practice Tip: Bring this framework to the mediation table. It streamlines discussions and avoids unproductive debates over what fraction of the electric bill is “child-related.” After Mehta, courts aren’t playing that game anymore, and neither should you.
Closing Thoughts: The Law Just Got More Realistic
Too often in mediation I hear, “She could work if she really wanted to.” But the law doesn’t require hypothetical earning potential—it requires us to look at what’s happening right now, in families dealing with disability, loss of income, or years of at-home caregiving.
Mehta v. Mehta doesn’t rewrite the spousal maintenance statute. It re-centers it in reality, and gives attorneys and mediators a more nuanced way to talk about fairness.
Need a Mediator Who Understands the Law—And Life?
Whether your client seeks maintenance or opposes it, I bring decades of legal experience and judicial perspective to every mediation. Let’s work together to reach a fair outcome.
My Spousal Maintenance Mediation Checklist is updated post-Mehta. Download it here.
