With no explanation, chose the best option from "A", "B", "C" or "D". caught in the middle of acrimonious custody battles, I agree with the Court’s holding that the Texas Family Code does not afford a trial court such discretion. But the treatment of attorney’s fees in modification and enforcement proceedings has been more complicated than the Court might indicate. I write separately to briefly explain this history and to illuminate why this subject has resulted in a lack of uniformity among the courts of appeals. I. The Common-Law Doctrine of Necessaries As the Court notes, the underpinnings of the doctrine of necessaries may be traced back over three centuries to English courts. 419 S.W.3d 292, 298-99 (citing Note, The Unnecessary Doctrine of Necessaries, 82 Mioh. L.Rev. 1767, 1767 (1984)). The doctrine implied a contract between a 101-02 (1889) (<HOLDING>); see also In re H.V., 252 S.W.3d 319, 327 n.

A: holding that attorneys fees are necessaries in a civil suit to recover money or property for the minor
B: holding that reasonable attorneys fees for the benefit of a minor in defending the minor against a criminal charge were necessaries
C: holding that trial court properly assessed mothers attorneys fees as necessaries against father in case in which trial court ordered father to pay mothers attorneys fees as child support but did not state that the fees were necessaries
D: holding that attorneys fees are necessaries for the criminal de fense of a child
D.