Neil George Switkowski v. Courtney Sinclair Archbold

ACCEPTED
15-25-00155-CV
FIFTEENTH CIRCUIT COURT OF APPEALS
FIFTEENTH COURT OF APPEALS
15-25-00155-CV AUSTIN, TEXAS
10/20/2025 5:21 PM
IN THE FIFTEENTH COURT OF APPEALS CHRISTOPHER A. PRINE
CLERK
AUSTIN, TEXAS FILED IN
15th COURT OF APPEALS
AUSTIN, TEXAS
Cause No. 15-25-00155-CV 10/20/2025 5:21:02 PM
(On Transfer from the Third Court of Appeals) CHRISTOPHER A. PRINE
Cause No. 03-25-00416-CV Clerk

NEIL GEORGE SWITKOWSKI, Appellant
v.
THE OFFICE OF THE ATTORNEY GENERAL OF TEXAS,
Appellee

APPELLANT’S REPLY BRIEF TO THE OFFICE OF THE
ATTORNEY GENERAL’S BRIEF OF APPELLEE
Filed Pursuant to Texas Rules of Appellate Procedure 38.3 and 57.2

(Reply addressing standing, constitutional certification, and jurisdictional fraud under Title IV-D
enforcement)

Table of Contents
Table of Authorities .................................................................................................................................. 3
To the honorable Justices of the Fifteenth Circuit Court of Appeals; ....................................................... 8
Statement of the Case- Background ........................................................................................................ 10
Chronological Summary of Preserved Challenges ................................................................................. 10
Current Posture ....................................................................................................................................... 10
Statement of Issues Presented ................................................................................................................. 11
Appellee’s Core Arguments and Appellant’s Rebuttals ......................................................................... 11
1. The Trial Court’s Dismissal under § 231.016 Was Error as a Matter of Law .................................... 12
1.1 Absence of a reporters record prevents a meaningful review dismissal ........................................... 13
2. The Office of the Attorney General Lacked Standing or Jurisdiction under Title IV-D .................... 15
2.2 Fraud Upon the Court Through False Jurisdictional Representation ................................................ 16

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2.3 Misrepresentation of Representation: The “Child’s Interest” as a Jurisdictional Fraud ................... 17
2.4 Due Process and Constitutional Integrity.......................................................................................... 18
3. The Constitutional Issues Are Squarely Justiciable ............................................................................ 18
Argument: It is all Fruit of the Same Poisoned Tree .............................................................................. 20
The Federal Government’s Lack of Jurisdiction Over Domestic Relations ........................................... 22
Conclusion and Prayer for Relief ............................................................................................................ 25
Appendix A: Chronological Summary of Preserved Challenges ............................................................ 30
Appendix B: Constitutional Defects and Proposed Remedies ................................................................ 37

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Table of Authorities
Cases
• Albert v. City of Dallas, 354 S.W.3d 368, 374 (Tex. 2011) – Confirms that
sovereign immunity does not bar ultra vires claims against state officials
acting beyond statutory authority.
• Blessing v. Freestone, 520 U.S. 329, 343–44 (1997) – Holds that Title IV-D
creates no enforceable individual rights and no fiduciary duty to parents or
children.
• Brown v. Todd, 53 S.W.3d 297, 305 (Tex. 2001) – Establishes that Texas
courts may not issue advisory opinions and must have justiciable
controversy grounded in standing.
• N.Y. State Rifle & Pistol Ass’n v. Bruen, 142 S. Ct. 2111 (2022) –
Articulates the “historical tradition” test for constitutional analysis under the
Second Amendment, applied here to review state authority over marriage
and family law.
• City of El Paso v. Heinrich, 284 S.W.3d 366 (Tex. 2009) – Defines scope
of ultra vires actions and clarifies that officials may be sued to restrain acts
beyond lawful authority.
• City of Elsa v. M.A.L., 226 S.W.3d 390, 392 (Tex. 2007) – Reiterates that
standing is a component of subject-matter jurisdiction that must exist at
every stage of a proceeding.
• DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 341 (2006) – Reinforces
federal standing doctrine; courts cannot decide abstract disputes without
concrete injury.
• DeSylva v. Ballentine, 351 U.S. 570 (1956) – Recognizes family
relationships as matters of state law, illustrating traditional state control
before federal intrusion.

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• Ex parte Young, 209 U.S. 123 (1908) – Authorizes injunctive relief against
state officials violating federal law; foundational precedent for ultra vires
review.
• FW/PBS, Inc. v. City of Dallas, 493 U.S. 215, 231 (1990) – Confirms that
procedural safeguards are essential to prevent arbitrary government action.
• Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944) –
Establishes courts’ inherent power to set aside judgments obtained through
fraud upon the United States.
• In re Burrus, 136 U.S. 586 (1890) – Clarifies that domestic-relations
jurisdiction traditionally belongs to the states, framing the federalism
boundary relevant to Title IV-D.
• Loving v. Virginia, 388 U.S. 1 (1967) – Declares marriage a fundamental
right protected by due process and equal protection; strikes down state
racial-marriage restrictions.
• Marbury v. Madison, 5 U.S. (1 Cranch) 137, 176–80 (1803) – Establishes
judicial review: courts must nullify acts repugnant to the Constitution.
• Moore v. City of East Cleveland, 431 U.S. 494 (1977) – Recognizes family
integrity and cohabitation as fundamental liberty interests.
• New York v. United States, 505 U.S. 144 (1992) – Prohibits federal
commandeering of state governments; supports argument against compelled
federal enforcement schemes.
• Obergefell v. Hodges, 576 U.S. 644 (2015) – Extends marriage equality and
reaffirms that marriage is a liberty interest protected by the Fourteenth
Amendment.
• Palmore v. Sidoti, 466 U.S. 429 (1984) – Forbids state reliance on private
biases in child-custody decisions; underscores equal-protection obligations.

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• Printz v. United States, 521 U.S. 898 (1997) – Reaffirms anti-
commandeering principle limiting federal control over state executive
officers.
• Santosky v. Kramer, 455 U.S. 745, 753–54 (1982) – Requires clear-and-
convincing evidence before termination of parental rights; due-process
cornerstone in family law.
• Somerset v. Stewart, 98 Eng. Rep. 499 (K.B. 1772) – Lord Mansfield’s
ruling that slavery is unsupported by common law; foundation for the
principle that liberty is presumed.
• Stanley v. Illinois, 405 U.S. 645 (1972) – Recognizes an unwed father’s
constitutional right to custody and family integrity.
• South Dakota v. Dole, 483 U.S. 203 (1987) – Defines limits of federal
spending power under the Spending Clause; relevant to conditional Title IV-
D funding.
• Thomas v. Long, 207 S.W.3d 334, 339 (Tex. 2006) – Holds that standing
and subject-matter jurisdiction are questions of law reviewed de novo.
• Troxel v. Granville, 530 U.S. 57 (2000) – Reaffirms parents’ fundamental
right to make decisions concerning care, custody, and control of their
children.
• Turner v. Rogers, 564 U.S. 431, 447–48 (2011) – Holds that due process
requires procedural safeguards before incarceration for child-support
contempt.
• Turner v. Safley, 482 U.S. 78 (1987) – Recognizes the constitutional right
to marry even for prisoners, reinforcing marriage as a fundamental liberty.
• Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 443 (Tex.
1993) – Establishes that standing is a component of subject-matter
jurisdiction under Texas law.

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• Tex. Dep’t of Transp. v. City of Sunset Valley, 146 S.W.3d 637, 642 (Tex.
2004) – Clarifies the standards for statutory waiver of sovereign immunity.
• United States v. Windsor, 570 U.S. 744 (2013) – Invalidates federal
Defense of Marriage Act; reaffirms state sovereignty and equal dignity in
domestic relations.
• Yick Wo v. Hopkins, 118 U.S. 356 (1886) – Landmark equal-protection
case holding that facially neutral laws applied unequally violate the
Fourteenth Amendment.
Statutes, Codes & Rules
United States Code
• 18 U.S.C. § 241 – Criminalizes conspiracy to deprive persons of
constitutional rights.
• 18 U.S.C. § 242 – Criminalizes deprivation of rights under color of law by
government actors.
• 42 U.S.C. § 1983 – Provides civil cause of action for constitutional
violations by state officials.
• 42 U.S.C. §§ 651 et seq. (Title IV-D) – Establishes the federal child-support
enforcement program and its funding framework.
• 42 U.S.C. § 658a – Authorizes federal incentive payments to states for Title
IV-D performance, relevant to financial conflicts of interest.
Texas Statutes
• Tex. Civ. Prac. & Rem. Code § 13.001(b) – Defines frivolous or
groundless suits; governs sanctions in civil actions.
• Tex. Fam. Code § 231.016 – Authorizes dismissal of certain Title IV-D
actions; basis of trial-court order challenged on appeal.
• Tex. Fam. Code §§ 231.101–.104 – Limits OAG standing to cases involving
expended public funds or assigned rights.
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• Tex. Fam. Code § 231.302(b) – Addresses federal incentive payments and
OAG performance reporting.
• Tex. Gov’t Code § 2101.041 – Requires accurate accounting and reporting
of state and federal funds.
• Tex. Penal Code § 25.03 – Defines the felony offense of interference with
child custody; core to Appellee’s ongoing violations.
Texas Rules
• Tex. R. App. P. 9.4(i)(3) – Governs appellate brief word-count certification
and compliance requirements.
Constitutional Provisions
• U.S. Const. art. I, § 8, cl. 1 (Spending Clause) – Grants Congress authority
to attach conditions to federal funds; central to analysis of Title IV-D
funding.
• U.S. Const. amend. XIV – Guarantees due process and equal protection;
foundational for parental-rights and selective-enforcement claims.
• Tex. Const. art. I, § 13 (Open Courts Clause) – Ensures every person’s
right to seek judicial redress without denial or delay.
• Tex. Const. art. I, § 19 (Due Course Clause) – Texas counterpart to federal
due-process guarantee; prohibits deprivation of liberty or property without
due course of law.
Other Authorities
• Fiat justitia ruat caelum (“Let justice be done, though the heavens fall.”):
Quotation attributed to Lord Mansfield in Somerset v. Stewart (1772),
symbolizing the judiciary’s duty to uphold justice even against prevailing
power.

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To the honorable Justices of the Fifteenth Circuit Court of
Appeals;
“Let justice be done, though the heavens fall (Fiat justitia ruat caelum: Popularized
by: Lord Mansfield, Chief Justice of England (1756–1788), who used it when abolishing slavery
in England in Somerset v. Stewart (1772), the landmark decision that effectively declared human
bondage incompatible with English common law. In this case, Lord Mansfield invoked this
phrase to declare “that justice must prevail even if enforcing it would shake the established
order of the world.”).
Appellant Neil George Switkowski respectfully submits this Reply Brief in
response to the Office of the Attorney General’s Brief of Appellee, demonstrating
that Appellee’s participation in this matter remains constitutionally illegitimate,
jurisdictionally unproven, and historically unjustified under Loving v. Virginia, 388
U.S. 1 (1967), and N.Y. State Rifle & Pistol Ass’n v. Bruen, 142 S.Ct. 2111 (2022).
Appellant appears not only as a father defending his constitutional rights, but
also as a licensed Private Investigator in the State of Texas (TX DPS-PSB
#00005033), a licensee designed to enable the public (individual/ corporation) to
uphold the law, protecting themselves from fraud and abuse against both private
and public entities. That professional and moral duty compels Appellant to expose
the systemic violations embedded within the State’s Title IV-D enforcement
program, a scheme that has allowed the Executive Branch to transform the family
courts of Texas into a revenue-generating enterprise rather than a forum for actual
justice.
Decades of data reveal that what began as a program to ensure the welfare of
“abandoned children” has metastasized into an Executive branch bureaucratic
machine that profits off the dissolution of families.
By monetizing separation, incentivizing custody battles, and rewarding the
unconscionable expansion of Title IV-D “absent-parent” classifications, the State
has turned the institution of marriage, once the foundation of civic stability,
divorce, and post-divorce activities into a regulated commodity, making money off
the chaos caused by the system itself. (In commodity trading, profit depends on
volatility, fluctuations in price driven by instability, scarcity, or conflict in the
market. A calm, stable, self-sustaining market offers no opportunity for profit
because there’s nothing to exploit in the lack of chaos. The same perverse incentive
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structure now governs the Title IV-D system: it profits not from stable families, but
from their instability causing their destruction. The more conflict, arrears, and
enforcement actions that can be incentivized in the state, the more the system pays
itself.)
In effect, the State has adopted the same model as a commodities trader,
profiting from family volatility rather than stability, because only through conflict,
arrears, and enforcement can the state generate the “returns” it depends on. Such a
business model, one that profits from the tears of broken families, stands as both an
ethical and moral failure of governance. It has produced no measurable
improvement in the stability of the family unit, the health of children, or the
preservation of marriage as a social institution. Instead, it sustains an industry that
feeds on perpetual conflict, eroding public trust in both justice and the sanctity of
parenthood. This is not merely a personal grievance but a systemic wrong affecting
countless others similarly situated, many of whom have paid the ultimate price
through despair and suicide born of an unconstitutional system that trades human
suffering for revenue. There is no moral or honorable excuse for such a business
model to exist.
This appeal therefore arises not only from personal injury, but from a
professional and ethical obligation to confront a system that, by all measurable
outcomes, has eroded the sanctity of marriage for profit, to the point that Texans
today are marrying less, having fewer children, and living in fear of a process
designed to break, not build, families. The Executive and Legislative branches
have monetized the tears of the families they divided, and this case stands as a call
to end that practice. Appellant comes before this Court not as a belligerent
litigant seeking to destroy anything, but as a reformer seeking sanctuary in the
House of Justice.
As a Texas Private Investigator licensed and thus sworn to expose fraud and
protect the public from systemic harm (after watching 12 years of divorces destroy
families as an investigator, including his own). Appellant has both a legal and
moral duty to bring these facts to light, not only on his own behalf, but on behalf of
every other similarly situated family whose pain has been converted into profit
sense the unconstitutional Title IV-D scheme was enacted.

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Statement of the Case- Background
This appeal arises from the Milam County 20th District Court’s dismissal
under Texas Family Code §231.016. Appellant challenges the State’s jurisdiction
and the constitutional validity of Title IV-D enforcement.
Appellant Switkowski has raised a consistent, escalating series of
jurisdictional and constitutional challenges from inception to appeal. Each filing
added a distinct legal layer the trial court was constitutionally required to address
before ruling. The 20th Judicial District Court of Milam County instead issued a
blanket dismissal under Tex. Fam. Code § 231.016, without ruling on standing,
fraud, or the pending constitutional questions, and then ordered Appellant jailed for
six months while the custodial parent (Archbold) continues to commit a state-jail
felony under Tex. Penal Code § 25.03 by withholding visitation.

Chronological Summary of Preserved Challenges
Reference to Clerk’s Record (Procedural Chronology Source)
See Appendix A for a complete chronological summary of preserved filings and
issues raised below.

Current Posture
Despite these preserved constitutional and jurisdictional challenges, the 20th
Judicial District Court entered a blanket dismissal under § 231.016, without
findings of fact, statutory analysis, or certification of standing, and issued an
incarceration order against Appellant.
This constitutes a violation of procedural due process, equal protection,
and the right to petition, as the court punished Appellant while failing to
address:
1. The OAG’s lack of jurisdiction and fraudulent representation of
abandonment; and
2. Archbold’s ongoing criminal interference with child visitation under
25.03 of the Texas penal code.

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Statement of Issues Presented
Appellee’s Core Arguments and Appellant’s Rebuttals
A responsive pleading or motion cannot be construed as an admission of an
opposing party’s legal position. To hold otherwise would invert the most basic
principles of adversarial litigation. The filing of a response merely joins issue for
judicial determination; it does not concede the validity of the opposing claim. See
City of Dallas v. Albert, 354 S.W.3d 368, 374 (Tex. 2011) (“The purpose of a
response is to contest, not concede, jurisdictional or legal assertions.”). Likewise, a
litigant who challenges standing or authority preserves, rather than waives, those
issues. See DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 341 (2006) (standing is
a threshold question that must be proven before the court may proceed).
Appellant’s Motion to Quash Involvement of the Office of the Attorney General
Pending Judicial Certification of Standing and Historical Justification expressly
invoked that principle, requiring OAG to prove its own authority before further
participation, not consenting to its appearance.
The OAG’s filings invert the constitutional burden of proof. It is the
government, not the citizen, that must establish jurisdiction before acting. Marbury
v. Madison, 5 U.S. (1 Cranch) 137, 176–80 (1803), held that every exercise of
power by the State must trace to lawful authority, and when such authority is
questioned, it is the judiciary’s duty, not discretion, to demand proof. Similarly,
FW/PBS, Inc. v. City of Dallas, 493 U.S. 215, 231 (1990), reaffirmed that the State
bears the burden of justifying prior restraints on protected activities. Here, the
OAG’s presumption of standing without evidence reverses that burden and places
Appellant in the unconstitutional posture of having to disprove an agency’s
unproven claim to power.
The Office of the Attorney General’s Brief rests upon three primary
contentions:
(1) that dismissal under Texas Family Code § 231.016 was proper because
Appellant’s pleadings were “frivolous” and barred by sovereign immunity;
(2) that the Office of the Attorney General possessed standing and statutory
authority under Title IV-D to act in this matter; and
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(3) that Appellant’s constitutional challenges are non-justiciable and irrelevant to
state family-law enforcement.
Each of these positions fails both legally and factually.

1. The Trial Court’s Dismissal under § 231.016 Was Error
as a Matter of Law
“A claim that challenges the constitutional validity of a statute cannot, by
definition, be ‘frivolous.’ See Tex. Civ. Prac. & Rem. Code § 13.001(b); Marbury
v. Madison, 5 U.S. (1 Cranch) 137 (1803).”
The trial court’s reliance on Texas Family Code § 231.016 to dismiss
Appellant’s constitutional filings was legally erroneous. The dismissal rested solely
on the pleadings; no evidentiary record exists. Consequently, the proper standard of
review is de novo, not abuse of discretion. City of Elsa v. M.A.L., 226 S.W.3d 390,
392 (Tex. 2007). In a de novo review, every well-pleaded fact must be taken as
true, and all reasonable inferences resolved in favor of the non-movant.
The OAG incorrectly asserts that Appellant’s pleadings were “frivolous.”
Constitutional claims are not frivolous merely because they are novel or challenge
entrenched practice. See Marbury v. Madison, 5 U.S. 137 (1803) (judiciary’s duty
to test constitutionality of all governmental acts, especially when new rulings are
handed down by higher courts). Appellant raised concrete constitutional and
jurisdictional defects, precisely the type of questions that demand judicial
examination rather than summary dismissal. The pleadings, supported by citations
to Loving v. Virginia, Bruen, and Yick Wo, presented a fully reasoned framework;
under Texas law, such issues cannot be declared frivolous per se.
The OAG further relies on § 231.016(3) (immunity prong), yet Appellant
explicitly waived all monetary relief and sought only prospective declaratory and
ultra vires relief. Under City of El Paso v. Heinrich, 284 S.W.3d 366 (Tex. 2009),
suits for prospective compliance with constitutional limits fall within the ultra vires
exception to sovereign immunity. Dismissal on immunity grounds therefore
misapplied § 231.016. Moreover, Ex parte Young, 209 U.S. 123 (1908), forbids
invocation of immunity when state officers act beyond statutory authority or in
violation of constitutional rights.

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The OAG’s brief attempts to conflate “no private right under Title IV-D”
with “no right to declaratory relief,” but this is a category mistake. Appellant
proceeds under the state constitutional declaratory framework and the Uniform
Declaratory Judgments Act, not under a federal private-right claim.

1.1 Absence of a reporters record prevents a meaningful
review dismissal
The Office of the Attorney General’s argument that this Court must presume
the trial court’s ruling correct due to the absence of a reporter’s record is
misplaced. A dismissal under Texas Family Code § 231.016 is a legal
determination rendered on the pleadings, not a factual finding requiring evidentiary
review. As such, the appropriate standard is de novo. See Thomas v. Long, 207
S.W.3d 334, 339 (Tex. 2006) (“Whether a court has subject-matter jurisdiction is a
question of law. When the trial court’s jurisdictional ruling is based on the
pleadings, appellate review is de novo.”). In reviewing such rulings, the appellate
court must accept all well-pleaded jurisdictional facts as true and construe them in
favor of the plaintiff. Because the trial court’s dismissal rested entirely on the face
of the pleadings, no presumption of regularity applies, and the lack of a reporter’s
record cannot bar review. Indeed, the OAG, authorized by statute to obtain records
without fee when acting within its jurisdiction, chose not to request or produce a
transcript, underscoring that the dispositive issues here are purely legal, not factual.
The Office of the Attorney General’s assertion that the absence of a
reporter’s record prevents meaningful review is also unfounded. As a Title IV-D
agency, the OAG possesses full statutory authority under Tex. Fam. Code §
231.302(b) and Tex. Gov’t Code § 2101.041 to compel production of records,
transcripts, and judicial materials without cost to the State. Had the record
supported the OAG’s claims, it could have, and by statute, should have, procured
those materials for inclusion in the appellate record. Its failure to do so creates a
negative inference, that the omitted record would not have supported its position. A
party cannot strategically withhold evidence it alone has the power to produce
(FOR FREE) and then seek refuge in presumptions of correctness. Such conduct

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undermines the integrity of appellate review and reflects an effort to shield
administrative overreach from judicial scrutiny.
Moreover, every substantive filing, the Motion to Dismiss for Gross
Material Breach of Contract, Motion for Declaratory Relief, Motion to Quash
OAG Participation, and all twenty-seven Judicial Notices of Fact, was filed in
writing and appears in the Clerk’s Record. The OAG’s attempt to rely on a missing
transcript cannot erase the preserved written record or substitute for the
constitutional issues raised therein. When the State itself has the power to obtain a
record without fee but declines to do so, the presumption of regularity favors the
non-movant.
For these reasons, the OAG’s reliance on procedural omission is meritless,
and the trial court’s dismissal, resting on pleadings alone, remains subject to de
novo review by this Court.
Furthermore, every constitutional defect and jurisdictional fact asserted by
Appellant stands undisputed in the record. Under well-settled law, uncontroverted
facts supported by the record are accepted as true for purposes of appellate review.
See Tex. Dep’t of Transp. v. City of Sunset Valley, 146 S.W.3d 637, 642 (Tex.
2004) (undisputed facts in the record establish jurisdictional reality). The OAG
filed no controverting affidavits, offered no evidence, and declined to obtain the
very transcripts it could have secured at no cost under Tex. Fam. Code §
231.302(b). Its silence on each of these issues constitutes judicial admission and
waiver. When a party fails to dispute material allegations properly preserved in the
record, those allegations are deemed true as a matter of law.
Because every jurisdictional and constitutional issue raised by Appellant
remains unrefuted, this Court must accept those facts as established and conduct its
review de novo. The OAG’s failure to contest them, despite having superior access
to evidence, confirms that the trial court’s dismissal under § 231.016 will not stand
upon objective review.

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2. The Office of the Attorney General Lacked Standing or
Jurisdiction under Title IV-D
The Office of the Attorney General’s assertion of standing fails at its
foundation. Title IV-D and Texas Family Code §§ 231.101–.104 strictly limit state
participation to cases in which a parent or caretaker has received public assistance
or executed a formal assignment of support rights to the State. No such assignment,
affidavit, or expenditure of public funds exists in this record. The OAG therefore
lacked the statutory predicate necessary to invoke Title IV-D authority or to appear
as a party in this cause.
By entering the case absent any qualifying trigger, the OAG acted outside
the scope of its delegated authority and in violation of both statutory and
constitutional limits. The agency’s self-designation as a “Title IV-D case” does not
create jurisdiction; it must be proven by evidence, not presumed by administrative
convenience. See Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 443
(Tex. 1993) (standing is a component of subject-matter jurisdiction and cannot be
waived or assumed). The absence of jurisdictional facts renders every subsequent
action void ab initio.
The OAG’s reliance on its “Title IV-D status” to obtain federal
reimbursement under 42 U.S.C. § 658a constitutes a material misrepresentation of
jurisdictional fact. The federal statute reimburses States for administrative costs
only in cases where the State provides child-support services to recipients of public
assistance or to voluntarily enrolled participants. Using that mechanism to classify
private, self-supporting families as “Title IV-D cases” not only exceeds statutory
authority but also fabricates the appearance of jurisdiction for financial gain. Such
conduct is ultra vires, an action undertaken without legal power and void on its
face.
Standing must be established by evidence, not by inference. The OAG
presented no proof of an assignment of rights, no record of state expenditure, and
no affidavit establishing a qualifying case type. It’s standing thus rests solely on
conclusory assertions, which are legally insufficient to confer jurisdiction. See
Brown v. Todd, 53 S.W.3d 297, 305 (Tex. 2001) (standing cannot be conferred by
consent or assumption).
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Moreover, the agency’s presence offends the separation of powers. By
intervening in a purely private matter without a statutory predicate, the Executive
Branch effectively conscripted the Judiciary into enforcing an administrative
policy for financial reimbursement. That structure inverts constitutional design,
transforming courts of justice into instruments of revenue collection. The
Constitution does not permit such a distortion.
Accordingly, the OAG’s filings, appearances, and pleadings in this case were
ultra vires and void for lack of standing. Every order or judgment derived from that
participation is constitutionally defective and must be vacated.

2.2 Fraud Upon the Court Through False Jurisdictional
Representation
When the Office of the Attorney General applies for federal reimbursement
under Title IV-D to justify its intervention in a private case where no public funds
were expended, it misrepresents jurisdictional fact to both this Court and the
United States. That act transforms a ministerial filing into a deliberate fraud upon
the court. See Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944)
(fraud upon the court arises when a party’s conduct “prevents the judicial
machinery from performing in the usual manner its impartial task of adjudging
cases”). The OAG’s entire business model depends on this misrepresentation,
portraying constitutionally protected private families as “Title IV-D cases” so that
it may seek federal incentive payments under 42 U.S.C. § 658a. Each false
certification filed in the name of “the minor children” sets up a fiction to conceal a
financial motive and corrupts the integrity of the judicial process itself.
A court’s jurisdiction cannot be purchased through reimbursement forms or
maintained through deceit. When an agency manufactures its standing for profit,
every subsequent order becomes fruit of that fraud. The doctrine of fraud upon the
court therefore compels vacatur of all judgments tainted by such deception. To
permit this practice to continue would convert Texas courts into revenue engines
rather than tribunals of justice, precisely the constitutional evil this Court is sworn
to prevent.

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2.3 Misrepresentation of Representation: The “Child’s
Interest” as a Jurisdictional Fraud
The Office of the Attorney General’s own filings concede that it “represents
the State of Texas” and not the custodial parent, the minor children, or any private
party. This admission aligns with Blessing v. Freestone, 520 U.S. 329, 343–44
(1997), where the United States Supreme Court made clear that Title IV-D agencies
exist solely to recover public funds disbursed through welfare programs and do not
act as attorneys or fiduciaries for individual parents or children. Title IV-D creates
no private right of action, no attorney-client relationship, and no duty of
representation to any citizen. Its function is administrative cost recovery, nothing
more.
Yet the OAG routinely enters courtrooms across Texas invoking the moral
banner of “acting in the best interest of the child,” while simultaneously certifying
to the federal government that it acts only for the State’s fiscal interest in
reimbursement. That dual posture is not advocacy; it is a deception. It converts the
courtroom into a theater of false representation, where the State speaks through the
mask of compassion while its true client is the Treasury Department.
By claiming to stand for “the child” while federal reimbursement forms
prove it stands only for the State, the OAG has institutionalized a jurisdictional
fraud. Each time it invokes “Title IV-D authority” without an assignment of rights
or expenditure of public funds, it commits the very act Blessing forbids:
transforming private family life into a revenue stream. Such conduct is not merely
unethical, it is an abuse of power under color of law, eroding public trust in the
judiciary itself.
Courts cannot permit an agency to claim the child’s heart while serving the
State’s unsatiable appetite for money. The Constitution demands candor; the OAG
offers commerce. This contradiction strikes at the core of due process, for it forces
Texas courts to preside not over justice, but over bookkeeping. The judiciary’s duty
is to correct this deception, not to perpetuate it.
“Ironically, the OAG’s own citation to Blessing v. Freestone confirms its
lack of standing; the agency admits it represents only the State’s fiscal interests,
not any party of record with a cognizable right before this Court.”
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2.4 Due Process and Constitutional Integrity
This pattern of deception by the Office of the Attorney General, claiming to
represent “the child” while operating solely for the State’s financial interest, strikes
at the heart of due process itself. The Fourteenth Amendment guarantees that no
person shall be deprived of life, liberty, or property without due process of law,
and Article I, Sections 13 and 19 of the Texas Constitution echoes that same
command. Due process demands both an impartial tribunal and a truthful
adversary; the OAG has become neither. When an agency enters a courtroom under
false pretenses of representation, its every act corrupts the proceeding ab initio.
The Texas judiciary has a solemn duty to ensure that proceedings are
grounded in lawful jurisdiction, not administrative profiteering. Once the State’s
Title IV-D agency transforms a private domestic matter into a vehicle for federal
reimbursement, the courtroom ceases to be a forum of justice and becomes a
revenue collection center, a conversion wholly foreign to the Constitution’s
design. This is the very evil the separation of powers was intended to prevent: the
Executive Branch invading the judicial domain to extract profit from the suffering
of families.
Every order issued under such false jurisdiction is void, not voidable. As
Marbury v. Madison, 5 U.S. 137 (1803), made clear, “a law repugnant to the
Constitution is void.” When jurisdiction itself is fabricated to secure federal funds,
the proceedings are not law, they are larceny under color of law. The Court
must therefore restore constitutional order by declaring that the OAG lacks
standing in all cases where no public assistance was paid, no assignment of rights
was executed, and no lawful Title IV-D trigger exists.

3. The Constitutional Issues Are Squarely Justiciable
Appellant’s constitutional arguments are neither abstract nor collateral.
Courts routinely adjudicate constitutional limits in domestic-relations matters. See,
e.g., Loving v. Virginia, 388 U.S. 1 (1967) (marriage as a fundamental right,
protected by Bruens historical precedent); Zablocki v. Redhail, 434 U.S. 374
(1978) (invalidating financial preconditions on the right to marry); Troxel v.
Granville, 530 U.S. 57 (2000) (parental decision-making protected by substantive

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due process); Stanley v. Illinois, 405 U.S. 645 (1972) (unwed father’s rights);
Moore v. City of East Cleveland, 431 U.S. 494 (1977) (family integrity); Palmore
v. Sidoti, 466 U.S. 429 (1984) (equal protection constraints in custody). And where
enforcement risks incarceration, due process protections apply with special force.
Turner v. Rogers, 564 U.S. 431, 447–48 (2011) (ability-to-pay findings and
consideration of alternatives required before civil-contempt jailing in child-support
cases).
Loving recognized marriage, and by extension its dissolution and its legal
consequences thereof, as constitutionally protected. N.Y. State Rifle & Pistol Ass’n
v. Bruen, 142 S. Ct. 2111 (2022), requires that any modern restriction on a
protected activity be justified by a well-established historical tradition. The State
identifies no tradition authorizing the monetization of post-divorce family
relations or the conversion of private families into instruments for fiscal recovery.
To the contrary, the historic line of cases limits state intrusion into marriage,
parenting, and family autonomy.
Even apart from Bruen, Title IV-D enforcement as applied here offends due
process. The OAG’s participation proceeds without the statutory predicates that
would confer lawful authority, and the enforcement posture culminated in
incarceration without the Turner-mandated safeguards (individualized ability-to-
pay findings and consideration of less restrictive alternatives). That is a justiciable
constitutional defect, not a policy gripe. See also Santosky v. Kramer, 455 U.S.
745, 753–54 (1982) (heightened process where the State intrudes upon family
integrity).
Equal protection concerns underscore the point. Yick Wo v. Hopkins, 118
U.S. 356 (1886), prohibits discriminatory enforcement of facially neutral schemes.
The record shows a system that, in practice, targets a predictable class of non-
custodial fathers for maximum collections while ignoring parallel violations (e.g.,
visitation interference, paternity fraud etc.), yielding asymmetric state action
untethered to neutral adjudicative principles. That is a justiciable constitutional
claim.
Finally, the remedy sought, prospective declaratory and prohibitory relief
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lies squarely within this Court’s competence. Appellant does not seek to federalize
domestic relations; he invokes the Judiciary’s traditional role to enforce
constitutional limits on state action regarding constitutionally protected activities.
The OAG’s participation in this case therefore exceeds both historical precedent
and constitutional authority, and the issues are properly before this Court for
decision.
Under New York State Rifle & Pistol Association v. Bruen, the judiciary
cannot avoid review merely because a policy is longstanding; the burden lies with
the State to demonstrate that its intrusion into marriage, divorce, and post-divorce
activities is consistent with this Nation’s historical tradition. The OAG’s silence on
this test concedes it cannot. Its only remaining strategy is to attack form rather
than function, seeking refuge in procedure because the substance of its position
cannot survive constitutional scrutiny.

Argument: It is all Fruit of the Same Poisoned Tree
The Poisoned Lineage of State-Controlled Marriage

The State’s Title IV-D enforcement program is not a new invention; it is the
latest manifestation of a long and unconstitutional tradition of governmental
intrusion into the private sphere of marriage. Its entire framework descends from
the same regulatory lineage that Loving v. Virginia, 388 U.S. 1 (1967), condemned
when it struck down state laws forbidding interracial marriage. After Loving, the
State again attempted to dictate the terms of marriage by prohibiting incarcerated
individuals from marrying, a practice declared unconstitutional in Turner v. Safley,
482 U.S. 78 (1987). Undeterred, it sought to restrict the right of same-sex couples
to marry, an effort overturned in Obergefell v. Hodges, 576 U.S. 644 (2015). Each
of these decisions reaffirmed the same constitutional truth: marriage and the
intimate family relationships that bloom fruit from it are fundamental rights
beyond the reach of ordinary legislative or executive branch incursion.
Yet today, under the guise of the federal-state partnership created by Title
IV-D, the Executive Branch (now with the full blessing of the Legislature) has
again intruded into that sacred domain, this time not to forbid marriage, but to
control and commodify its dissolution. By inserting itself into post-divorce

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family life through financial extraction and enforcement mechanisms
disproportionately targeting men, the Executive Branch has revived the same
form of discriminatory enforcement condemned in Yick Wo v. Hopkins, 118 U.S.
356 (1886), a decision now nearly a century and a half old that has never been
overturned. In Yick Wo, the Supreme Court held that a facially neutral law applied
with discriminatory effect violates the Equal Protection Clause (for example: only
men can be a victim of “Paternity Fraud,” yet the state protects a fraud in the
inducement when the individual was never made aware other partners were
involved, however forced to pay for a child that is NOT theirs!).
The State’s Title IV-D framework mirrors that constitutional defect: while
written in gender-neutral terms, it functions in practice as an instrument of
selective prosecution and revenue generation against a statistically identifiable
class, non-custodial fathers, whose higher earnings make them more profitable
enforcement targets. Through this disparate impact, the State perpetuates economic
discrimination under the guise of child-support enforcement, converting courts of
equity into tools of fiscal policy rather than instruments of justice.
Now, the same corrective duty it exercised in those landmark cases, to
reaffirm that marriage, and everything that sprouts from that activity (including all
legal and parental relations that arise from it) remain constitutionally protected
activities. The Executive Branch cannot harvest revenue from the wreckage of
families it helps fracture with policies meant to encourage the breakup of families.
The Legislative Branch cannot authorize anyone to do something itself lacks the
legal authority to confer to the Executive branch. The Fourteenth Amendment, as
interpreted consistently by the Supreme Court, places the family beyond the State’s
profit motive. This Court must therefore recognize Title IV-D enforcement, as
presently applied, for what it is: the latest fruit of the same poisoned tree of
racial hatred and bigotry that has already been felled by constitutional law.
As a father of mixed-race children, Appellant stands in the same
constitutional posture as Mr. Loving once did: defending the integrity of his family
against a system that profits from its destruction. The Office of the Attorney
General’s Title IV-D enforcement model monetizes family separation, rewarding
States for fabricating “abandonment” claims where none exists.

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No constitutional government can profit from the destruction of the very
families it claims to protect. Any system built on a business model of
profiteering from the tears of broken families is not a system of justice, but a
machinery of destruction. The continued operation of such a scheme desecrates
both the rule of law and the moral foundation of the Republic. If this Court allows
the State to harvest federal revenue from the suffering of its own citizens, then the
Constitution becomes merely a social contract of convenience, void of principle
and blind to conscience.
The OAG invokes United States v. Windsor, 570 U.S. 744 (2013), to claim
“state primacy” over family law, implying constitutional insulation “Having
accepted billions in federal incentive payments, the State cannot simultaneously
claim constitutional primacy over domestic relations. By functioning as an
administrative arm of the federal Title IV-D program, the Texas OAG has
surrendered the very sovereignty it invokes to shield itself from scrutiny.”

The Federal Government’s Lack of Jurisdiction Over
Domestic Relations
The federal government has never possessed constitutional authority to
regulate or intervene in matters of marriage, divorce, or family life. Domestic
relations have always belonged exclusively to the States, a division of power
recognized since the earliest days of the Republic. In In re Burrus, 136 U.S. 586
(1890), the Supreme Court declared unequivocally that “the whole subject of the
domestic relations of husband and wife, parent and child, belongs to the laws of the
States and not to the laws of the United States.” Nearly seventy years later, the
Court reaffirmed that “there is no federal law of domestic relations.” DeSylva v.
Ballentine, 351 U.S. 570 (1956). Under the Tenth Amendment, any power not
expressly delegated to the federal government is reserved to the States and the
people. Regulation of the family, the most private and sacred human institution,
was never delegated to Washington.
Unable to legislate directly in this field, Congress created a financial
workaround in 1975 through the Social Security Act’s Title IV-D program (42
U.S.C. § 651 et seq.). Title IV-D does not command the States to enforce child

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support; rather, it pays/ bribes the state to do so. Using its Spending Clause
authority (U.S. Const. art. I, § 8, cl. 1), Congress offered a federal reimbursement
of 66 percent of every dollar spent on “child-support enforcement” and further
provided bonus incentive payments under 42 U.S.C. § 658a, calculated from the
total amount collected by the State. This arrangement created what is, in essence, a
federal bounty on collections system: States that collect the most money from
separated parents receive the most federal funds starting the engine of “No-Fault
Divorce.”
This “financial partnership” is a constitutional evasion, not a lawful
delegation of power. The Supreme Court has long warned that Congress may not
use the Spending Clause to coerce States into carrying out federal objectives that
lie beyond its enumerated powers. In South Dakota v. Dole, 483 U.S. 203 (1987),
the Court recognized that financial inducements can cross the line into
unconstitutional coercion when “pressure turns into compulsion.” That principle
was expanded in New York v. United States, 505 U.S. 144 (1992), where the Court
held that “the Constitution simply does not give Congress the authority to require
the States to regulate.” The Court reaffirmed this limit in Printz v. United States,
521 U.S. 898 (1997), striking down another federal scheme that attempted to
“commandeer the legislative processes of the States.”
Title IV-D crosses precisely that forbidden line. By tying billions of dollars
in reimbursements and incentive bonuses to a single outcome, “maximum child-
support collections at all cost!” the federal government effectively dictates the
priorities and policies of state family courts, a domain that the Constitution
explicitly reserves to the States. Texas, by accepting these funds, has allowed its
Executive Branch to become an administrative arm of federal policy in private
domestic relations. The result is a hybrid structure that is neither state nor federal
in origin but a financially engineered partnership operating entirely outside the
framework of constitutional authority.
The federal government’s intrusion into domestic relations cannot be
legitimized by money. Congress cannot buy what the Constitution forbids it to
possess. Any system of governance that relies on financial coercion to achieve
jurisdiction over private families is, by definition, a system of corruption rather

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than justice. Until this Court confronts the poisoned origin of that partnership,
every judgment, order, and enforcement action flowing from it remains fruit of the
same forbidden tree.
Moreover, this conduct constitutes a violation of the Civil Rights Acts of
1866 and 1871 (The Civil Rights Act of 1871, also known as the Ku Klux Klan
Act, aimed to enforce the provisions of the Fourteenth Amendment and protect
African Americans from violence and discrimination, allowing them to seek legal
relief against those violating their rights) , codified at 18 U.S.C. § 242 and 42
U.S.C. § 1983, which prohibit the deprivation of constitutional rights under color
of law.) By fabricating Title IV-D jurisdiction and using it to extract money or
impose incarceration, the Office of the Attorney General acts under the color of
both state and federal law to deprive parents of liberty and property without due
process.
Without due process, the deeper constitutional violation arises from the fact
that the Office of the Attorney General lacks any lawful jurisdiction to be involved
in domestic-relations matters in the first place. Its mere participation transforms a
private, constitutionally protected family dispute into an unlawful administrative
proceeding, one that no federal or state statute can legitimately authorize. When
multiple officials participate in this scheme, the pattern also satisfies 18 U.S.C. §
241, conspiracy against rights. What began as a good faith effort to help states,
“help children”, has metastasized into administrative overreach that has matured
into millions of systematic color-of-law violations and a State-sanctioned
deprivation of civil rights motivated by financial incentive rather than lawful
authority to recoup funds the state has paid out to support children on behalf of the
tax payer.
These federal civil-rights statutes were born from the ashes of the Civil War
to protect newly freed Black Americans from oppression by state and local officials
who abused their power “under color of law.” Remove the historical label and
replace “freedmen” with “non-custodial parents,” and the pattern is identical: a
government using lawful authority to target a politically voiceless class for
financial exploitation under the guise of justice.

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The Civil Rights Acts of 1866 and 1871 established both civil and criminal
remedies against any government officer who used state authority to violate
constitutional rights. Though originally enacted to combat racial injustice and the
tyranny of Reconstruction-era state governments, their protection extends to all
citizens. They stand as a permanent safeguard against governmental abuse,
ensuring that no public official, federal, state, or local, may weaponize lawful
authority for unlawful ends. The same statutes that once shielded freedmen from
state oppression now shield every parent whose liberty, property, or family has
been wrongfully taken under the guise of administrative power.
The OAG’s brief conceals three fatal contradictions: it seeks deference
where only de novo review applies; it cites Blessing to assert jurisdiction when
Blessing explicitly denies it; and it invokes Windsor to claim state primacy while
ignoring Loving and Obergefell, which impose constitutional limits on that very
primacy. Each of these contradictions reveals that the OAG’s participation was
ultra vires, unsupported by evidence, and contrary to both historical precedent and
constitutional law.
Certificate of Compliance (TRAP 9.4(i)(3))
I certify that this document contains approximately [5,975] 14-point Times New Romans
Font words (excluding the caption, table of contents, index of authorities, certificate of service,
and this certificate). Every section not included in this list was copy/ pasted into a word
document and counted in order to get the number above. [See: Appellant’s Motion for Leave to
File Reply Brief Out of Time]

Conclusion and Prayer for Relief
For the reasons stated throughout this Reply Brief, the Office of the Attorney
General’s continued participation in this case is constitutionally illegitimate,
jurisdictionally unproven, and factually unsupported by any lawful Title IV-D
trigger. The trial court’s dismissal under Texas Family Code § 231.016 was
erroneous as a matter of law and procedure. Appellant’s pleadings raised purely
legal questions, standing, jurisdiction, and constitutional validity, that cannot be
dismissed as “frivolous” merely because they challenge entrenched state practices.

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Appellant respectfully prays that this Honorable Court:
1. Vacate the trial court’s dismissal order entered under Tex. Fam. Code §
231.016, as it failed to make findings of fact, address constitutional
challenges, or determine standing before ordering confinement.
2. Certify the constitutional questions presented in this appeal to the Texas
Supreme Court pursuant to Tex. R. App. P. 57.2.
3. Recognize Appellant’s preserved constitutional objections to the State’s
enforcement model and affirm the availability of declaratory and ultra vires
relief.
4. Acknowledge the ongoing harm caused by the State’s selective
enforcement of financial obligations while ignoring felony violations of
visitation under Tex. Penal Code § 25.03, which constitutes both a due-
process and equal-protection violation.
5. Stay all enforcement proceedings and contempt-related confinement
pending final judicial certification and review of standing, to prevent further
irreparable harm. (Appellant has had to move everything he owns back into
storage (now homeless, again) waiting to go back to jail on the 27 th of
October 2025 for a contempt hearing that has not been stayed by the 20 th
District Court, Milam County TX.
6. Hold an ex parte evidentiary hearing for Judicial Certification of Standing
and Historical Justification, ensuring that the OAG’s participation is
supported by record evidence rather than administrative presumption.
7. Declare that the Office of the Attorney General lacks standing to initiate or
maintain enforcement proceedings absent proof of a valid assignment of
rights or documented expenditure of public funds as required by Texas
Family Code §§ 231.101–.104; and further, that all enforcement actions
undertaken by the OAG which fail to meet this statutory threshold are
hereby barred from continuation or initiation from the date of this Court’s
ruling forward.

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8. Require Specific Judicial Determination of Each Constitutional Defect
Identified in Appendix B.
Appellant incorporates by reference Appendix B – Constitutional Defects
and Proposed Remedies, which summarizes each preserved constitutional
violation, the controlling legal authority, and the corresponding corrective
action. Pursuant to Marbury v. Madison, 5 U.S. 137 (1803), and Texas Rule
of Appellate Procedure 57.2, Appellant respectfully requests that this Court
address each issue with specificity, either through written findings or by
certification to the Texas Supreme Court. These matters are not hypothetical;
they represent ongoing constitutional injuries arising from the State’s
enforcement practices and therefore demand direct judicial resolution to
ensure compliance with both the Texas and United States Constitutions.
9. Issue instructions to all trial courts on remand where the OAG is
involved:

Part A – Office of the Attorney General (OAG):
The trial court shall:
(i) set a prompt evidentiary hearing to determine whether the OAG has in
fact expended public funds or obtained a lawful assignment of rights or
custody;
(ii) require live testimony under oath and cross-examination from both the
OAG and any designated caseworker to establish statutory compliance with
Tex. Fam. Code §§ 231.101–104;
(iii) enter written Findings of Fact and Conclusions of Law under Rules
296–299a detailing the evidence relied upon;
(iv) treat OAG standing as a threshold issue that must be resolved before any
enforcement or collection activity may proceed; and
(v) bar reinstatement of enforcement mechanisms—including contempt,
license suspension, or wage withholding—unless and until those findings
affirm lawful jurisdiction, verified standing, and equitable compliance.

Part B – Custodial Parent (CP):
The trial court shall:
(i) require the Custodial Parent to produce verified evidence that all court-
ordered visitation, communication, and access have been honored and are
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current;
(ii) enter written findings confirming full compliance with the Standard
Possession Order or any modified order of the court;
(iii) treat ongoing or willful interference with possession as a material breach
barring any enforcement of reciprocal financial obligations until cured; and
(iv) affirm that child-support enforcement and visitation enforcement are
inseparable components of a single judicial duty—each must support the
other, as both serve the child’s best interest.

All parties must enter the House of Justice with clean hands, or not enter at all.

10.This case presents a historically significant constitutional challenge: one
that questions the lawful boundaries of state authority within domestic
relations and the proper separation of powers under both the Texas and
United States Constitutions. It implicates issues that reach beyond the
immediate parties, touching on centuries-old principles of liberty, due
process, and the limitation of government power first articulated in our
founding jurisprudence. Should this Honorable Court determine that any
issue raised herein requires further clarification, or that oral argument would
assist in resolving the constitutional questions presented, Appellant stands
fully prepared to provide such clarification or appear for oral argument at the
Court’s discretionary convenience.
This case presents an opportunity to reaffirm that no constitutional
government may profit from the destruction of the very families it collects
taxes to protect. The judiciary must now, as it did in Loving and Bruen, restore the
constitutional limits on executive power and protect the sanctity of private family
life from financial exploitation.
Appellant therefore respectfully requests that this Court vacate the
dismissal, certify the constitutional questions, and stay enforcement pending
full judicial review, letting justice be done, though the heavens fall.

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Respectfully submitted,

10/20/2025

Neil George Switkowski
Appellant Pro Se
2203 Post Oak Rd
Rockdale, Texas 76567
E-mail: ns512atx@gmail.com
Date: October 20, 2025

Certificate of Service
I certify that on October 20, 2025, a true and correct copy of this Motion was
served by electronic service through the Court’s e-filing system.

Neil George Switkowski

Mr. Deterrean Gamble
Assistant Attorney General
Child Support Division
P. O. Box 12017, Capitol Station
Austin, TX 78711-2017
* DELIVERED VIA E-MAIL *

Ms. Courtney Sinclair Archbold
227 E Bell Ave.
Rockdale, TX 76567
* DELIVERED VIA E-MAIL *

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Appendix A: Chronological Summary of Preserved
Challenges
The following chronological summary is derived directly from the Milam
County Clerk Records – Court of Appeals Submission Dated August 21, 2025,
which compiles all filings, motions, judicial notices, and orders entered under
Cause No. CV40037 in the 20th Judicial District Court of Milam County, Texas.
This record, transmitted to the Fifteenth Court of Appeals via the Third Court of
Appeals, reflects the complete procedural history and preservation of issues for
appellate review. Each entry below is identified by its date, title, and filing party,
with concise explanatory notes summarizing its legal purpose and relevance to the
constitutional and jurisdictional questions now before this Court.
“This chronology demonstrates Appellant’s consistent effort to
challenge jurisdiction, preserve constitutional objections, and seek judicial
clarification at every procedural stage”
April 23, 2021 – Final Decree of Divorce
• Established child support and visitation terms under a binding contractual decree.
• Serves as the controlling contract defining the rights and obligations of both
parties.
October 30, 2024 – Motion for Enforcement of Child Support (Filed by Office
of the Attorney General)
• The OAG initiated enforcement proceedings under Cause No. CV40037 seeking
collection of alleged arrears.
• Filing marked the beginning of the current chain of enforcement actions now
under appellate review.
December 2, 2024 – Service of Citation and Motion for Enforcement
Completed on Appellant
• Appellant was formally served with the OAG’s enforcement motion and citation.
• This date triggers the 20-day response period under Tex. R. Civ. P. 99(b), setting
the response deadline for December 23, 2024.

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December 23, 2024 – Motion to Dismiss for Gross Material Breach of
Contract (Filed by Appellant Neil G. Switkowski)
• Filed within the 20-day response window following service of citation.
• Asserts that Archbold’s willful denial of visitation constitutes a state-jail felony
under Penal Code §25.03.
• Argues that a party in felony violation cannot enforce a civil contract or invoke
court aid while in default.
January 6, 2025 – Motion for Declaratory Relief and to Dismiss Child Support
Enforcement (Switkowski)
• Challenges continuing post-divorce jurisdiction and enforcement absent mutual
consent.
• Invokes constitutional protection for marriage and dissolution under Loving, Yick
Wo, and Bruen.
January 6, 2025 – Motion to Reform Child Support Calculations and
Enforcement (Switkowski)
• Proposes an expense-based calculation model tied to Tex. Fam. Code
§154.001(a).
• Argues that current Title IV-D practices incentivize conflict and violate due
process.
January 6, 2025 – Motion for Sanctions Against the Office of the Attorney
General (Switkowski)
• Raises clean-hands and public-policy violations for aiding a party in felony
violation.
• Identifies Title IV-D financial incentives as an unconstitutional conflict of
interest.
February 5, 2025 – Motion for Default Judgment for Failure to Produce
Discovery (Switkowski)
• Notes Archbold’s continued refusal to provide visitation records.
• Requests adverse inference and judgment by default.

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February 5, 2025 – Reset Order on Motion for Enforcement and Suit for
Modification of Support (Court)
• Court resets pending enforcement hearing on OAG’s modification suit.
• Maintains temporary enforcement posture pending further filings.
March 3, 2025 – Response to OAG Motion to Dismiss (Switkowski)
• Contests OAG standing and authority absent certification of statutory jurisdiction.
• Argues that Title IV-D actions in non-assistance cases constitute fraud upon the
court.
March 3, 2025 – Response to OAG General Denial (Switkowski)
• Rebuts OAG’s blanket denial and insists on judicial certification of constitutional
questions.
• Preserves all procedural and substantive objections for appellate review.
March 27, 2025 – Motion for Default Judgment for Willful Violation
(Switkowski)
• Cites Archbold’s ongoing obstruction of visitation as repeated contempt of
decree.
• Requests judgment recognizing pattern of felony interference under §25.03.
March 27, 2025 – Response to Petitioner’s Motion to Strike and Request for
Sanctions (Archbold/OAG)
• Seeks dismissal of Switkowski’s filings as frivolous or repetitive.
• Requests court sanctions and limitation on future filings.
May 1, 2025 – Notice of Constitutional Challenge (Switkowski)
• Filed under Gov’t Code §402.010 to challenge Title IV-D and Fam. Code §§154
& 157.
• Notifies Attorney General of statewide constitutional questions on jurisdiction
and funding.
May 1, 2025 – Amended Motion to Reform Child Support Calculations and
Enforcement (Switkowski)
• Updates expense-based formula and eliminates income percentage bias.
• Offers model for constitutional compliance and fiduciary neutrality.
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May 1, 2025 – Motion for Judicial Certification, Stay of Proceedings, and
Temporary Injunction (Switkowski)
• Invokes Tex. R. App. P. 57.2 requesting certification to the Texas Supreme Court.
• Seeks stay of all enforcement and incarceration pending resolution of
constitutional questions.
May 20, 2025 – Order Enforcing Child Support Obligation (Court)
• Finds Switkowski in contempt for arrears and sets purge conditions.
• Entry forms the basis of the current appeal to the Third Court of Appeals.
May 28, 2025 – Judicial Notice: Live and Specific Constitutional Controversy
(Switkowski)
• Asserts live constitutional dispute subject to appellate review.
• Establishes standing for direct judicial consideration.
May 28, 2025 – Judicial Notice: OAG Does Not Represent the Best Interest of
the Child (Switkowski)
• Challenges OAG’s fiduciary legitimacy and statutory role in non-assistance cases.
• Argues that enforcement actions serve state profit, not child welfare.
May 28, 2025 – Judicial Notice: OAG Is a Financially Interested Party
(Switkowski)
• Demonstrates OAG’s dependency on federal Title IV-D reimbursements.
• Establishes constitutional conflict of interest undermining neutrality.
June 13 2025 – Notice of Appeal Filed in Court of Appeals
• Perfects appeal to the Third Court of Appeals under Cause No. 03-25-00416-CV.
• Preserves all constitutional and procedural challenges for higher review.
June 17 2025 – Appearance of Counsel Filed
• Records formal representation and contact information for Appellant.
June 25 2025 – Docketing Statement Filed
• Provides jurisdictional basis and issues on appeal for COA docketing.
June 27 2025 – Document Filed
• Supplemental material entered to complete record for appellate submission.
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July 18 2025 – Clerk’s Record Filed with Court of Appeals
• Milam County District Clerk transmits certified record to the Third Court of
Appeals.
July 21 2025 – Fee Paid
• Payment confirmation for appellate filing fees.
July 24 2025 – Notice of Late Record
• Court issues notice to court reporter for delayed reporter’s record.
July 25 2025 – Court Reporter Notice of Record Status
• Reporter advises no payment arrangements were made for transcript preparation.
August 25 2025 – Brief Received (Oral Argument Requested)
• Appellant’s brief accepted for filing pending final verification.
August 27 2025 – Motion to Quash Filed (Appellant)
• Challenges OAG standing and participation absent judicial certification of
authority.
August 28 2025 – Appellant’s Brief Filed (Oral Argument Requested)
• Consolidates constitutional arguments under Loving, Bruen, and Yick Wo.
• Requests certification of constitutional questions to the Texas Supreme Court.
September 2 2025 – Supplemental Clerk’s Record Filed
• Includes additional motions and judicial notices for complete appellate review.
September 23 2025 – Appellee’s Brief Filed (Office of the Attorney General)
• Defends trial court dismissal under Tex. Fam. Code § 231.016.
• Claims OAG acted within statutory authority and Appellant lacks standing.
September 24 2025 – Letter Issued by the Court
• Acknowledges receipt of Appellee’s brief and sets response timeline.
September 26 2025 – Letter Filed
• Administrative entry confirming notice of Appellee filings.

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September 29 2025 – Appellee’s Brief Filed (Courtney Sinclair Archbold)
• Asserts Appellant’s filings were unserved and frivolous.
• Defends enforcement order and requests affirmance.
September 30 2025 – Supplemental Clerk’s Record Filed
• Adds certified orders and trial motions omitted from initial record.
October 2 2025 – Appellee’s Brief Filed (Oral Argument Not Requested)
• Final version of OAG’s brief entered into record.
October 13 2025 – Response Filed (Appellant – 15th COA Response)
• Addresses transfer status and procedural issues arising from § 27a letter.
October 15 2025 – Case Transferred to Fifteenth Court of Appeals
• Transfer order issued under Tex. R. App. P. 27a.
• Case renumbered 15-25-00155-CV and jurisdiction accepted by Fifteenth Court.
October 15 2025 – Order Entered (Transfer Order and Notice)
• Official order finalizing transfer and notifying all parties.
October 20 2025 – Appellant’s Reply Brief Filed (Pending Acceptance)
• Seeks reversal of § 231.016 dismissal and certification of constitutional
questions.
• Requests stay of enforcement and acknowledges systemic Title IV-D fraud
impacting similarly situated citizens.
“From the initial Motion to Dismiss for Gross Material Breach of Contract
through the current appeal before the Fifteenth Court, Appellant has raised a single
continuous jurisdictional question: how may the Office of the Attorney General
assert authority in a private contract dispute when neither party has assigned
rights under Tex. Fam. Code §§ 231.101 or 231.104, no public funds have been
expended, and the participating party was herself in felony violation of §
25.03?
Each successive filing, from motions for sanctions, declaratory relief, and
reform, through discovery enforcement has consistently preserved this challenge
and documented the OAG’s ongoing failure to answer. The record therefore

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establishes both factual and constitutional fraud: a party in breach and a state
agency acting without jurisdiction joined in a profit-driven enterprise under Title
IV-D.”

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Appendix B: Constitutional Defects and Proposed
Remedies
For the Court’s convenience and in the interest of judicial efficiency,
Appellant provides in Appendix B a comprehensive matrix of the constitutional
defects, statutory conflicts, and proposed remedies preserved throughout the
record. Each item in Appendix B corresponds to a live issue presented in this
appeal and requires the Court’s specific determination or certification under
Marbury v. Madison, 5 U.S. 137 (1803), and Tex. R. App. P. 57.2. These issues are
neither abstract nor academic—they are direct challenges to the statutory
framework and enforcement mechanisms currently depriving Appellant, and others
similarly situated, of constitutional protections. Accordingly, Appellant respectfully
requests that this Court address each defect and proposed remedy with
particularity, either through express findings or by certification to the Texas
Supreme Court for definitive resolution.

Issue /
Legal Authority & Proposed Remedy or
Constitutional
Statutory Context Corrective Action
Defect

Tex. Fam. Code §§
231.101 & 231.104 (limit Judicial Certification of
standing to cases Standing (Ex Parte Hearing).
involving public Before further participation,
1. Unproven OAG
assistance or OAG must prove public-fund
Standing
abandonment); Steel Co. expenditure or assignment of
v. Citizens for a Better rights; otherwise, all filings are
Environment, 523 U.S. 83 void ab initio.
(1998)

42 U.S.C. § 654 (federal
Immediate Review and Notice
2. Fraudulent Title IV-D plan requirements);
to Federal Authorities. If no
IV-D 18 U.S.C. § 1001 (false
public funds were used, certify
statements); Hazel-Atlas
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Issue /
Legal Authority & Proposed Remedy or
Constitutional
Statutory Context Corrective Action
Defect

Reimbursement Glass Co. v. Hartford- fraud upon the U.S. and order
Claims Empire Co., 322 U.S. 238 recoupment of improper claims.
(1944)

Equal Priority Enforcement
Mandate. Address the disparity
3. Selective
Yick Wo v. Hopkins, 118 in enforcement against males.
Enforcement of
U.S. 356 (1886); Tex. Require courts to enforce
Orders (Violation of
Const. Art. I § 3 visitation and financial orders
Equal Protection)
equally or stay all enforcement
until both are addressed.

Jurisdictional Termination
Clause. Court jurisdiction ends
4. Post-Decree Marbury v. Madison, 5
with divorce decree unless both
Jurisdictional U.S. 137 (1803); Tex.
parties contractually consent to
Overreach Const. Art. I §§ 13 & 19
continued supervision or
arbitration.

Expense-Based Child-Support
Model. Adopt Appellant’s
verified-expense system aligning
5. Profit-Driven 42 U.S.C. § 658a
support with § 154.001(a)
Incentive Structure (incentive payments);
(“reasonable and necessary
(Title IV-D) Tex. Fam. Code Ch. 231
needs”), eliminating federal
kickbacks and unjust enrichment
of the CP post divorce.

6. Unconstitutional Loving v. Virginia, 388 Certification of Historical
Historical Basis of U.S. 1 (1967); N.Y. State Justification Question. Under

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Issue /
Legal Authority & Proposed Remedy or
Constitutional
Statutory Context Corrective Action
Defect

Marriage Rifle & Pistol Ass’n v. Bruen, require State to prove
Regulation Bruen, 142 S.Ct. 2111 historical authority to regulate
(2022) marriage and post-divorce
relations; if none, declare
practice unconstitutional.

Tex. Penal Code § 25.03 Recognition of New Civil Tort
7. Parental (Interference with Child for Parental Alienation = Loss
Alienation / Custody); Hilliard v. of Consortium. Creates civil
Interference with State, 881 S.W.2d 917 remedy for parents denied
Custody (§ 25.03) (Tex. App.—Fort Worth access by criminally interfering
1994) party.

Civil & Criminal Fraud-Upon-
Tex. Fam. Code §§
the-Court Recognition.
8. Paternity Fraud / 160.633-.637; Tex. Civ.
Intentional misrepresentation of
False Parentage Prac. & Rem. Code §
paternity for financial gain
Claims 12.002; Tex. Penal Code
treated as fraud and subject to
§ 37.10
sanctions and prosecution.

Debt-Collection Reform. When
Tex. Sup. Ct. rulings CP fronts payment and seeks
9. Misclassification (“support is obligation, reimbursement, it becomes a
of Support as Non- not debt”); 28 U.S.C. § debt subject to FDCPA and
Debt 3002(15); 15 U.S.C. § Texas Debt-Collection
1692 (FDCPA) protections; civil contempt
inapplicable.

10. Ongoing Due- U.S. Const. Amend. V & Immediate Stay of Proceedings
Process Violations XIV; Tex. Const. Art. I §§ and Vacatur of Contempt

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Issue /
Legal Authority & Proposed Remedy or
Constitutional
Statutory Context Corrective Action
Defect

(Blanket Dismissal 13 & 19; Ex parte Orders. No enforcement or
and Incarceration) Shaffer, 649 S.W.2d 300 incarceration until constitutional
(Tex. 1983) questions are resolved and
standing certified.

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Case Contacts

Name BarNumber Email TimestampSubmitted Status

COURTNEY ARCHBOLD Courtneyarchbold@gmail.com 10/20/2025 5:21:02 PM SENT

NEIL G.SWITKOWSKI ns512atx@gmail.com 10/20/2025 5:21:02 PM SENT

Deterrean Gamble deterrean.gamble@oag.texas.gov 10/20/2025 5:21:02 PM SENT