Brown v. Brown (1975)
In Brown v. Brown, 521 S.W.2d 730 (Tex.App.-Houston 14th Dist. 1975, no writ), the respondent husband was served with citation and appeared with counsel at a show-cause hearing, although he did not file any written document which could be considered as a pleading.
Judgment of divorce was subsequently entered without notice to the husband, and husband appealed.
The court of appeals held that even though the husband appeared in the suit, absent a written pleading, the case was uncontested and advance notice of the final hearing was not required by the rules of civil procedure or the local trial court rules. Id. at 732.
The appellant in Brown did not contend that his due process rights were violated.