The Fort Worth Court of Appeals rejected the argument that a trial court has “no authority to award attorney’s fees as part of a just and right division of the community estate because the property was divided by an agreement of the parties rather than the court.” The court affirmed an attorney’s fee award of $92,867 plus conditional fees on appeal of $27,500. Gibson v. Gibson, No. 02-12-00177-CV (Tex. App. – Fort Worth Jan. 23, 2014) (mem. op.).