After the Pope Trilogy of 1967, Slavin was not cited by another case until Ex parte Sandefer, 461 S.W.2d 193 (Tex.App.–Eastland 1970, no writ) (per curiam). It’s a bit of a conundrum.
The opinion is short, not even 800 words. Though it cites Slavin for the proposition that to be enforceable by contempt, a decree must “set out the details of compliance in clear, specific, and unambiguous terms,” the opinion does not quote or provide the specific language at issue in the decree. It paraphrases the decree and states that the decree prohibited the parents from removing the children from the jurisdiction without the other parent’s consent or a court order. Yet the mother, Darlene Sandefer, moved with the children from Taylor County, Texas, to Dallas County–conduct the trial court found was in contempt of the judgment. Moving with the children to another county without the other parent’s consent or court permission might appear to violate the provisions, yet the court of appeals ordered Mrs. Sandefer discharged and held that the decree did not in clear, specific and unambiguous terms “make it mandatory that Mrs. Sandefer and the children live at the Abilene address.” Without knowing what the decree actually said, it’s hard to ask the question of whether or not the court of appeals got it right, much less divine some guidance for future cases.