In the context of divorce litigation, fraud on the community estate falls within the wide spectrum of various acts frequently termed as "marital fraud." Prior to the passage of Section 7.009 of the Texas Family Code, the Texas Supreme Court's opinion in Schlueter was considered to be the authority on remedies available to an innocent spouse in a divorce involving fraud on the community estate. See Schlueter v. Schlueter, (Tex. 1998). In Schlueter, the Texas Supreme Court reasoned that because...