The Dallas Court of Appeals recently held that contempt is not available to enforce contractual spousal support absent decretal language in the divorce decree along with a reference to Chapter 8 of the Texas Family Code and its requirements. Here, the parties entered into an agreement for spousal maintenance. The final divorce decree, however, simply incorporated the agreement by reference and included no decretal language. Moreover, neither the decree nor agreement referenced Chapter 8 and its requirements, or evidenced an intent by the parties that Chapter 8 would govern the support obligations. Consequently, the Court held that the agreement to pay support was merely a contractual debt for which contempt was not an available remedy. Accordingly, the Court affirmed the trial court’s dismissal of the enforcement petition. The Court’s opinion in In the Interest of L.R.P. and H.A.P. can be found here.