This question has been addressed in 1 Texas court opinion:
COA05 — January 30, 2026
After losing his job, a father sought to terminate his child support obligation but refused to produce discovery documents regarding his retirement accounts and foreign property interests. The trial court granted a directed verdict against him, denying the modification and imposing a $4,800 discovery sanction. The Dallas Court of Appeals affirmed the denial of the modification, holding that a party seeking to change support must provide full financial transparency to allow the court to calculate "net resources." However, the court reversed the monetary sanction because the trial record lacked specific evidence, such as attorney fee invoices or testimony, to justify the $4,800 amount.
Litigation Takeaway
“Transparency is mandatory in support modification cases; losing your primary income does not excuse you from disclosing your broader financial estate. Additionally, any party seeking discovery sanctions must ensure the record contains specific evidentiary proof linking the amount of the sanction to the actual costs or fees incurred.”