Alfonso v. Skadden
In Alfonso v. Skadden, 251 S.W.3d 52 (Tex. 2008) (per curiam), an ex-husband sought to enforce a child custody provision contained in a default divorce decree that was more than four years old. 251 S.W.3d at 53.
His ex-wife claimed the trial court lacked both subject matter and personal jurisdiction to enforce the provision. Id.
The supreme court looked at the entire record and concluded the trial court lacked subject matter jurisdiction because Texas was not the child's home state. Id. at 55.
However, the supreme court never addressed the issue of personal jurisdiction, nor did it hold that in a collateral attack courts may look beyond the face of the judgment in determining the existence of personal jurisdiction. Id.