A Texas appeals court has rejected a father's attempt to become the guardian of his daughter's estate, ruling that his financial interests conflicted with hers. The court also upheld an order requiring him to pay attorney's fees to his former wife.
According to the October 22, 2026, opinion published by Justia, the Texas Eleventh Court of Appeals affirmed a lower court's decision to reject LaNoard Murad Bayouth's application to manage his daughter Addison Kay Bayouth's estate. The judges found that his separate effort to reduce his child support payments could potentially lower the total money received for his daughter's benefit.
The ruling upheld the trial court's findings that the guardianship application was filed in bad faith and without just cause.
Dispute centred on child support and Social Security benefits
According to the court's opinion, LaNoard was required to pay $2,650 a month in child support for Addison. She also received $1,829 in monthly Social Security benefits on his behalf because of his disability.
LaNoard had filed a separate petition seeking to have the Social Security payments credited against his child support obligation. If approved, the adjustment would reduce his monthly child support payment to $821.
He argued that the proposed credit was permitted by law and would not change the overall amount attributed to his support obligation. However, the appeals court noted that it would reduce the total amount his former wife, Tammie Lynn Bayouth, received for Addison's benefit, as she currently receives both payments on her daughter's behalf.
The court clarified that it was not deciding whether LaNoard was legally entitled to the proposed adjustment. That question would have to be resolved in the separate child support modification proceeding.
Court found the father's interests conflicted with his daughter's
The appeals court considered LaNoard's attempt to obtain guardianship alongside his pending effort to reduce the money paid for Addison's benefit.
The judges concluded that seeking to turn part of the Social Security benefits into a credit against his own child support obligation created an interest contrary to his daughter's financial well-being. Under Texas law, that adverse interest meant he lacked standing to apply for guardianship of her estate.
The court also noted that arrangements were already in place to manage Addison's finances. Tammie served as her representative payee, while a special needs trust had been established for Addison's benefit.
Father raised concerns over the management of funds
LaNoard argued that his application was justified because Tammie had initially deposited Addison's backdated Social Security benefits into her personal account for four months, had not timely completed representative payee reporting and had delayed opening a separate account for the funds.
However, the appeals court said the trial court was entitled to give limited weight to this evidence. It noted that LaNoard acknowledged during the hearing that a special needs trust was an alternative to guardianship and that he had no concerns about how First Financial Trust and Asset Management Company was managing the existing trust.
He also acknowledged that Tammie was already the representative payee and that Addison had no substantial personal property beyond nominal personal effects.
The judges said his testimony conflicted with claims in his application that alternatives to guardianship were not feasible. This supported the lower court's finding that the application had been filed without just cause.
Court upholds attorney's fees, finds application was filed in bad faith
The appeals court also rejected LaNoard's challenge to the award of attorney's fees to Tammie. Under Texas law, fees may be assessed against a party who pursues or contests a guardianship application in bad faith or without just cause.
The court noted that LaNoard filed his guardianship application approximately two weeks after amending his petition to modify his child support obligation. Given the timing, the trial court could reasonably conclude that he was attempting to circumvent the pending child support proceedings and gain control over Addison's property.
The judges said the existing arrangements for Addison's benefits, together with LaNoard's conflicting testimony and the timing of the application, supported the trial court's findings.
The appeals court therefore affirmed the lower court's order, leaving intact its decision that LaNoard lacked standing to seek guardianship of his daughter's estate and that attorney's fees should be awarded to Tammie.