Texas Family Code §157.002: What Specificity Actually Means for Your Enforcement Motion

The Specificity Requirement That Sinks Most Enforcement Motions

Texas Family Code §157.002 is deceptively simple on its face. It requires that a motion to enforce an order for child support "must include" certain elements — but the specificity requirement buried in subsection (c) is where most enforcement motions run into trouble.

When opposing counsel files a special exception to your enforcement motion, §157.002(c) is almost always the target. Here's exactly what the statute requires — and how to draft violations that survive it.

What §157.002(c) Actually Requires

Section 157.002(c) of the Texas Family Code provides that for each alleged violation, the motion must state with specificity:

1. The date of the alleged violation
2. The manner of the alleged violation
3. The amount of child support owed — for monetary obligations

These are not optional. Each element must appear in each violation paragraph. Missing one element in any violation is enough for opposing counsel to successfully specially except that allegation out of your motion.

Compliant vs. Non-Compliant Pleading Examples

Non-Compliant (Will Not Survive Special Exception)

This fails on all three elements. No specific dates, no specific manner of non-compliance for each payment period, no specific amounts per violation.

Also Non-Compliant (Common Mistake)

This is better but still deficient. It groups three violations into one paragraph. Courts have held that each violation must be separately pleaded — one paragraph per violation date.

Compliant — The Correct Structure

Three violations, three separate paragraphs. Each has a specific date ("on or about January 1, 2026"), a specific manner ("failed to pay the monthly child support payment"), and a specific amount ("$500.00"). This structure survives a special exception.

The "On or About" Language

Note the use of "on or about" before the date. This is intentional and provides important protection. Child support is typically due on the first of the month, but the obligor may have until the 5th or 10th before the payment is technically late. The "on or about" language avoids creating a technical deficiency if the exact due date varies slightly from the pleaded date.

Pleading Partial Payments

When the obligor makes partial payments, the manner and amount pleading must reflect the actual shortfall:

Visitation Violations: Different Specificity Rules

For custody and visitation enforcement motions, the manner of violation is different but the structure is the same. Each denied visit must be separately pleaded:

Building Your Arrears Calculation

After pleading each violation, your motion should include a summary paragraph calculating total arrears. This gives the court a clear picture of the total amount owed and makes it easier to draft the enforcement order if your motion is granted.