Court Filings

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 most of a trial court’s April 19, 2024 agreed order in a suit to modify the parent–child relationship between Russell Lerner and Geraldine Schott, but removed a requirement that Lerner post a $25,000 bond before filing any future pleadings. The court held Lerner cannot appeal terms he expressly agreed to at the April 9, 2024 hearing (such as lifting geographic restrictions, dismissal of pending motions, child-support and fee provisions), and he waived claims about findings of fact and docket management. The bond requirement was improper because the court never followed Texas statutory procedures for declaring a party a vexatious litigant.

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 First Court of Appeals denied a pro se petition for a writ of mandamus filed by Ryen Michelle Staggers seeking to vacate and stay enforcement of a March 27, 2026 temporary order from a Harris County family-court case. The appellate court concluded Staggers failed to provide the mandatory mandamus record or appendix that includes a certified copy of the challenged trial court order, as required by the Texas Rules of Appellate Procedure. Because the court could not review the order, it found she had not shown entitlement to mandamus relief and therefore denied the petition and dismissed pending motions as moot.

The Texas Third Court of Appeals granted mandamus relief to Meredith Johnson (Mother) after the trial court denied her motion to compel the production of the father’s federal income tax returns for the past two years in a child-support case. The appeals court held that Family Code § 154.063 requires parties in child-support proceedings to produce two years of tax returns and other financial information, the returns are relevant to determining net resources and above-guideline support, and the trial court’s denial was a clear abuse of discretion. The court ordered the trial court to vacate its order denying the motion and to compel production of the tax returns.

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 Seventh Court of Appeals abated and remanded an appeal from an order terminating J.P.'s parental rights because the reporter's record, due March 16, 2026, was not filed and the reporter failed to respond to the court's inquiries. The appellate court directed the trial court to determine what remains to complete the record, why the reporter has not completed it, how much time is needed, and whether a substitute reporter is necessary. The trial court must ensure admitted exhibits are included, address the reporter's repeated late filings, make written findings, and file a supplemental clerk's record by April 17, 2026.

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 Fourth Court of Appeals (San Antonio) denied Camoray Wathen-Escobar’s original petitions for a writ of mandamus and a writ of habeas corpus and denied as moot her emergency motion for temporary relief. The court explained mandamus requires showing a clear abuse of discretion and lack of an adequate appellate remedy, and that the intermediate appellate court lacks jurisdiction over family-code habeas petitions regarding return of a child. After reviewing the petition and record, the court concluded the relator did not meet the standards for relief and therefore denied the petitions.

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 dismissed an appeal filed by Grant Allen Nelson from a final divorce decree entered July 7, 2025, after Nelson filed an unopposed motion stating he no longer wished to prosecute the appeal. Because no other party appealed and the motion complied with Texas appellate procedure, the court granted the motion, dismissed the appeal, and denied as moot any other pending motions. The decision is procedural and does not address the merits of the underlying divorce decree.

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 Court of Appeals for the First District of Texas granted the appellant Erica Arnez Jackson's motion for voluntary dismissal of her appeal from a judgment of the County Court at Law No. 2, Galveston County (trial court case no. 25-FD-0597). Because no opinion had issued, the court dismissed the appeal under Texas Rule of Appellate Procedure 42.1(a)(1) and dismissed any other pending motions as moot. The decision is a procedural dismissal rather than a merits determination.

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.