Court Filings

The Tenth Court of Appeals reviewed Father's appeal of a trial court order terminating his parental rights to four children. Counsel filed an Anders brief concluding the appeal is frivolous, and Father submitted a pro se response. The appellate court conducted a full review of the record, found sufficient evidence to support the trial court’s findings that Father violated Family Code §161.001(b)(1)(D) and (E) and that termination was in the children’s best interest, and affirmed the termination order. The court denied counsel’s motions to withdraw because they did not show independent good cause under Texas law.

The Tenth Appellate District of Texas affirmed the trial court’s dismissal of Appellant’s bill of review challenging a July 26, 2022 order that terminated his parental rights to A.A.C.C. The Department moved for traditional summary judgment, arguing a six-month statutory bar under Texas Family Code §161.211(a) prevents collateral or direct attacks on such termination orders. Appellant did not file any response to the summary judgment motion. The court held the Department met its burden by showing the termination was under §161.002(b) and the bill of review was filed well after the six-month deadline, so the petition was time-barred.

The Texas Ninth Court of Appeals affirmed a trial court order terminating both parents’ rights to infant Ivy after a jury found, by clear and convincing evidence, statutory grounds D, E, and N and that termination was in the child’s best interest. The Department of Family and Protective Services removed Ivy after she arrived at the hospital with a fractured femur, liver laceration, and bruising; testimony and medical opinions raised serious abuse concerns and showed parental instability and untreated mental-health issues. The court also upheld appointment of the Department as managing conservator and denied Mother’s mistrial claim about an improper juror communication.

The Eleventh Court of Appeals affirmed a trial court’s final order terminating a mother’s parental rights to her eight children. The appeals court reviewed the record after counsel filed an Anders brief concluding there were no nonfrivolous issues, independently reviewed the record, and agreed the mother’s appeal lacked merit. The trial court found by clear and convincing evidence that the mother endangered the children through substance abuse, constructively abandoned them, and failed to complete court-ordered substance treatment, and that termination was in the children’s best interest. The appeals court denied counsel’s motion to withdraw and affirmed the termination order.

The Eleventh Court of Appeals affirmed a trial court’s final order terminating a mother’s parental rights to her child. The appellate court found clear and convincing evidence that the mother endangered the child through substance abuse and related conduct, failed to comply with a court-ordered plan, and that termination was in the child’s best interest. Because the legislature repealed one statutory predicate ground after the proceedings began, the court modified the trial court’s written order to delete the now-void finding under subsection (O). The court denied counsel’s withdrawal and required counsel to pursue further appellate remedies if appropriate.

The Court of Appeals of the Second Appellate District of Texas affirmed the trial court’s December 10, 2025 order terminating Father’s parental rights to A.M. The Department of Family and Protective Services had petitioned to terminate under multiple statutory grounds. Father challenged one predicate ground and alleged due-process defects in the Department’s timelines and service plan, but he did not challenge the other independent predicate findings or preserve the service-plan complaint for appeal. Because at least one unchallenged statutory ground and the best-interest finding supported termination, the appellate court affirmed.

The Texas Court of Appeals affirmed the trial court’s denial of Raymond T. DeMeritt’s motion to terminate child-support withholding. DeMeritt, declared the father in a 1985 legitimation decree, sought termination claiming he had overpaid and that garnishment was improper. The Office of the Attorney General submitted accounting reports showing DeMeritt owed arrears and interest; the trial court held an evidentiary hearing and found DeMeritt owed $30,990.57 as of January 6, 2025. The appeals court found the trial court did not abuse its discretion, noting DeMeritt failed to rebut the OAG’s accounting or meet his burden of proof.

The Fourth Court of Appeals affirmed a trial court’s modification appointing J.A.V.S. as sole managing conservator and C.R. as possessory conservator of two children. The mother, C.R., appealed but repeatedly failed to follow appellate briefing rules, including providing record citations and legal argument. The court struck her initial brief, accepted an inadequate amended brief, and found no reporter’s record for the November 20, 2025 modification hearing, so the appellate record did not show what evidence the trial court considered. Because C.R.’s submissions provided nothing for review, the court affirmed the modification order.

The Texas Sixth Court of Appeals affirmed the trial court’s termination of Mother’s parental rights to her infant child, E.T. The Department removed the child shortly after birth when both tested positive for amphetamine and later showed Mother’s continued methamphetamine and other drug use, untreated bipolar disorder, failure to complete court-ordered services, and periods of incarceration and mental-health treatment. The court applied the statutory best-interest factors (Holley factors) and concluded that Mother’s instability, ongoing substance use, untreated mental-health issues, and failure to complete services supported a finding by clear and convincing evidence that termination was in the child’s best interest.

The appellate court affirmed the trial court’s Final Decree of Divorce between Chukwuemeka Carl Runyon and Bianca Bazile Runyon. After a bench trial, the trial court divided the community estate, appointed both parents joint managing conservators, gave the mother the right to determine the child’s primary residence (with a geographic restriction allowing residence in Brazos County or within 50 miles of Orlando, Florida), and ordered father to pay $1,840 per month in child support. The court found no abuse of discretion in the property division, the relocation decision, or the refusal to grant a child-support credit for travel expenses, given the record and applicable family-law standards.

The Court of Appeals affirmed the trial court’s order terminating the mother’s parental rights to twin children R.H. and E.H. after reviewing an accelerated appeal challenging whether termination was in the children’s best interest. The court applied Texas statutory standards and Holley factors, giving deference to factfinder credibility determinations. It found clear-and-convincing evidence the mother’s persistent methamphetamine use, failure to comply with services and testing, association with an abusive partner, and instability endangered the children and made reunification unsafe. The children were bonded with and well-cared for by their maternal aunt and her husband.

The Eleventh Court of Appeals affirmed the trial court’s enforcement order and final judgment enforcing a divorce decree property award in favor of Pamela Sheehan. George Sheehan had spent or moved funds that the divorce decree had awarded from a specific bank account, so the trial court converted the award into a money judgment for $64,601.44 plus $6,200 in attorney’s fees. The appeals court held the enforcement judgment was a permissible enforcement remedy under the Family Code, not an unauthorized modification of the divorce decree, and the award of attorney’s fees was authorized.

The Court of Appeals of the Second Appellate District of Texas affirmed a trial court order terminating Father’s parental rights to A.S. after a bench trial. Mother had petitioned to terminate, alleging Father failed to support the child and that termination was in the child’s best interest. The appellate court found legally and factually sufficient evidence to support the trial court’s finding that Father failed to provide support in accordance with his ability during the relevant twelve-month period and that termination was in A.S.’s best interest, noting the child’s distress over visits, the child’s improved well-being since visits stopped, and Father’s financial choices and reliance on his fiancée to pay household expenses.

The Texas Seventh District Court of Appeals affirmed the trial court’s judgment terminating Mother’s parental rights to her child, T.C.-J., after the Texas Department of Family and Protective Services removed the child due to suspected prenatal and ongoing methamphetamine exposure. The jury found statutory grounds for termination and that termination was in the child’s best interest. The appellate court rejected Mother’s challenges because she failed to preserve complaints about the sufficiency of the best-interest evidence and about admission of prior Department history by not making the required trial objections or motions.

The court affirmed a default final order terminating or modifying parental rights after Mother obtained substituted service and a default hearing while Father did not appear. Father filed a restricted appeal arguing substituted service and service returns were defective, certain certificates were filed prematurely, and the clerk failed to send notice of judgment. The court concluded Father met the procedural requirements for a restricted appeal, found his briefing on several points inadequate, and determined nothing in the record showed error on its face; therefore the trial court’s default final order was affirmed.

The Fourth Court of Appeals affirmed the trial court’s order terminating Mother’s parental rights to four children. The Department had filed for termination after repeated removals tied to Mother’s chronic methamphetamine use and related instability, including leaving a child in a home with a person against whom a protective order had been obtained. The appellate court found the evidence legally and factually sufficient to support statutory grounds (D) and (E) — that Mother’s conduct and the children’s environment endangered their physical and emotional well‑being — and also held termination was in the children’s best interests based on the children’s repeated disruptions, their expressed desire to remain with relatives, and the relatives’ ability to provide permanency.

The First District Court of Appeals affirmed the trial court’s order terminating the father’s parental rights to his six-year-old son, Z.A.A., and leaving the Department of Family and Protective Services (DFPS) as sole managing conservator. DFPS sought termination so the child’s maternal great-grandfather, who had provided long-term stable care and planned to adopt, could become permanent conservator. The court found by clear-and-convincing evidence that DFPS made reasonable efforts to reunify the child with father and that termination was in the child’s best interest given father’s repeated incarcerations, criminal history, lack of contact, and the child’s improved stability in the great-grandfather’s home.

The First District Court of Appeals of Texas affirmed the trial court’s final decree terminating Mother’s and Father’s parental rights to four minor children. The parents argued lack of jurisdiction due to timing and challenged the sufficiency of evidence on reasonable efforts, predicate grounds, and best interest. The appellate court held the earlier trial commencement was not a sham, so jurisdiction was proper. The court found clear-and-convincing evidence that both parents engaged in conduct and allowed conditions that endangered the children (Family Code §161.001(b)(1)(D) and (E)) and that termination served the children’s best interests given parental substance abuse, violence, instability, probation violations, incarceration, and the children’s special needs.

The Court of Appeals of the Eighth District of Texas affirmed a trial court judgment that terminated the father's parental rights to his child, J.K.C. After a bench trial the trial court found termination was in the child's best interest and that the Department of Family and Protective Services proved grounds under Texas Family Code section 161.001(b)(1)(D), (E), and (N). Appellate counsel reviewed the record under Anders procedures and the court conducted an independent review, finding no non-frivolous issues to support reversal. The court also denied counsel's motion to withdraw, preserving the father's right to appointed counsel through further review.

The Texas court of appeals affirmed a trial court order terminating S.A.’s parental rights to her infant daughter, B.G.A.Y. The Department of Family and Protective Services removed the child after she tested positive for opioids and methadone at birth and after evidence of parental heroin and cocaine use. At trial the caseworker testified S.A. failed to complete treatment, had sporadic contact with the Department, did not visit during conservatorship, and did not submit to drug testing. The court found statutory grounds for termination and concluded termination was in the child’s best interest, given the parents’ substance abuse and the child’s stable foster placement with prospective adoptive caregivers.

The court affirmed the trial court’s dismissal of a Texas divorce suit after the trial court recognized a prior Mexican divorce decree. The ex-husband filed the Mexican no-fault divorce and later presented the Mexican trial and appellate judgments in Texas, arguing the Texas court lacked subject-matter jurisdiction because the parties were no longer married. The Texas appellate court held the trial court did not abuse its discretion in giving comity to the Mexican judgment, concluding the Mexican appellate court’s affirmation meant no valid marriage existed for a Texas court to dissolve, so dismissal was proper.

The Court of Appeals affirmed the trial court’s order terminating Mother’s and Father’s parental rights to two children, Timothy (11) and Richard (5), and appointing the Department of Family and Protective Services as permanent managing conservator. The parents raised multiple challenges, including untimely trial, insufficiency of evidence on best interest and statutory predicate grounds, ineffective assistance of counsel, and a constitutional strict-scrutiny claim. The court found the trial was timely, the evidence was legally and factually sufficient to support termination and best-interest findings, Father received effective counsel, and existing procedural and substantive protections were adequate to address his constitutional complaint.

The Eleventh Court of Appeals affirmed a Midland County trial court’s final divorce decree awarding spousal maintenance to Aletha Marie Dominguez. Oscar Dominguez argued (1) the maintenance award was unsupported and (2) the decree improperly limited his ability to seek future modification. The appeals court found the evidence, including testimony, financial statements, and the trial court’s findings, supported the determination of Aletha Marie’s minimum reasonable needs ($5,200/month) and that she lacked sufficient property at dissolution. The court also held any perceived restriction on seeking modification was moot or a permissible discretionary periodic-review provision.

The Fourth Court of Appeals affirmed the trial court’s May 2024 order terminating Mother C.A.’s parental rights to infant G.M.L. The Department of Family and Protective Services had removed the children after repeated concerns about Mother’s substance use, hazardous home conditions, and a domestic-violence incident. The appeals court held that the Department gave fair notice and presented clear-and-convincing evidence that it made reasonable reunification efforts and that a continuing danger remained in Mother’s home, supporting termination and appointment of the Department as permanent managing conservator.

The First District of Texas affirmed the trial court’s order terminating the mother’s parental rights to her nine-year-old twins and awarding sole managing conservatorship to the Department of Family and Protective Services (DFPS). The court reviewed an accelerated appeal from a bench trial and found the evidence legally and factually sufficient to show the mother knowingly placed or allowed the children to remain in endangering conditions (unsanitary, no utilities, presence of feces and urine, reports of physical abuse) and that termination was in the children’s best interest. The court relied on the children’s improved stability and care in their foster home, the mother’s criminal history, repeated positive drug tests, failure to complete services, and prior dangerous living conditions to support its decision.

The First Court of Appeals of Texas affirmed a trial court's modification of a 2016 custody order that named Carolyn Pena sole managing conservator and restricted George E. Saldana’s visitation. Saldana, representing himself, argued the trial was void because a recusal motion was pending, he lacked adequate notice of the trial, and his arrest and detention around trial made the proceedings unfair. The court held that a “tertiary recusal” statute allowed the trial judge to proceed, that the record shows Saldana had actual notice more than 45 days before trial, and that the trial court did not abuse its discretion in denying a new trial despite the arrest and security incidents.

The First District of Texas affirmed the divorce decree in Ada U. Oguamanam v. Tony Oguamanam. Ada argued on appeal that she was harmed because the trial court signed findings of fact and conclusions of law that she did not receive notice of, preventing her from timely requesting additional findings. The court held that Ada failed to show the required injury — she could have requested additional findings after learning of them or sought abatement but did not — and that the proposed additional findings she identified were largely evidentiary or unnecessary to decide the controlling issues. The judgment is affirmed.