In Finley v. May, 154 S.W.3d 196 (Tex. App. Austin--2004, no pet.), the Court observed that "the legislature specifically distinguishes between the assessment of fees and costs in enforcement actions as opposed to modification suits because of the potentially serious consequences that stem from an award of fees as child support"--namely that "attorney's fees awarded as child support are not viewed as debt and may be enforced by contempt." Id. (citing Tex. Fam. Code Ann. 157.167). Because the Court determined that the attorney's fees at issue in Finley were awarded in a suit to modify the parent-child relationship and not to enforce delinquent child support payments, we held that the trial court erred in assessing attorney's fees as child support. Id.