Court Filings

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 Eighth District Court of Appeals affirmed the Cuyahoga County Domestic Relations Court’s order keeping a one-year civil domestic violence protection order (DVCPO) in place against B.S. (“Stepfather”). Father filed for the DVCPO after Stepfather pushed his son T.H. into a wall twice in November 2024, causing a concussion; CCDCFS substantiated physical abuse and a municipal temporary protection order accompanied a related criminal case. The magistrate found the child-abuse evidence credible and the trial court overruled Stepfather’s objections. The appellate court held the continuance and the DVCPO were not an abuse of discretion and were supported by the record.

The Ohio Tenth District Court of Appeals affirmed the juvenile court’s decision granting permanent custody of two-year-old A.S. to Franklin County Children Services (FCCS), thereby terminating the parental rights of mother L.S. After FCCS filed for permanent custody following nearly two years of involvement because of mother’s mental-health crises, housing instability, and inconsistent engagement with case-plan requirements, the juvenile court found permanent custody was in the child’s best interest. The appeals court held the trial court did not abuse its discretion in denying a day-of-trial continuance and that mother failed to show she received ineffective assistance of counsel or that any alleged deficiency prejudiced her case.

The Ohio Sixth District Court of Appeals affirmed the juvenile court’s September 9, 2025 decision awarding Lucas County Children Services (LCCS) permanent custody of the minor E.D.-P. The child had been adjudicated dependent and temporarily placed with paternal relatives in Texas; LCCS later sought permanent custody. The appellate court held the juvenile court properly found by clear and convincing evidence that R.C. 2151.414(E)(11) applied because Mother had previously had parental rights involuntarily terminated to a sibling and failed to prove she could now provide a legally secure, adequate permanent placement. The court found Mother remained cohabiting and dependent with the child’s father, who showed no engagement in parenting, and the record supported the juvenile court’s findings that reunification was not feasible within a reasonable time.

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 Georgia Court of Appeals considered an application for discretionary appeal in a child-related case styled In the Interest of M. B. (Mother). After review, the court denied the application for discretionary appeal, meaning it declined to hear the matter on appeal. The order is ministerial and contains no additional reasoning or discussion of the underlying juvenile or parental rights proceedings.

The First District Court of Appeals affirmed the juvenile court’s denial of a mother’s 2024 motion to regain legal custody of her two children, B.B. and R.W. The juvenile court and magistrate found the mother failed to prove changed circumstances since the 2018 legal-custody disposition to father. The court concluded the evidence (photos, medical summaries, and testimony) did not substantiate abuse or medical neglect by father nor show missed medical care produced harmful consequences sufficient to overcome the statutory presumption of permanency for juvenile-court custody orders.

The Ohio Court of Appeals affirmed a juvenile court judgment awarding permanent custody of infant J.J. to Lucas County Children’s Services (LCCS). The agency filed an original permanent-custody complaint two days after J.J.’s birth based on parents’ extensive prior child-welfare history, unresolved substance-use, housing, and domestic-violence concerns, and prior involuntary termination of parental rights to siblings. The trial court found by clear and convincing evidence that the parents had not rebutted the presumption in R.C. 2151.414(E)(11) and that awarding permanent custody to LCCS was in J.J.’s best interest, so parental rights were terminated.

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.

The Georgia Court of Appeals dismissed a direct appeal filed by Chuka Anene from a trial court’s final judgment and decree of divorce because appeals in divorce and other domestic relations matters require a discretionary-appeal application under OCGA § 5-6-35. The court explained that compliance with the discretionary appeals procedure is jurisdictional and cited precedent holding the same. Because the appellant did not follow that mandatory procedure, the Court of Appeals concluded it lacked jurisdiction and dismissed the appeal on April 7, 2026.

The Court of Appeal affirmed the family court’s orders vacating a default judgment in a marital dissolution case and denying the petitioner’s request for a statement of decision, then remanded for further proceedings. The court held the default judgment exceeded the relief requested in the form petition because the petition left property division items as “to be determined,” so the entry of a default awarding specific property violated the respondent’s due process right to notice. The court also concluded Family Code set-aside provisions and Code of Civil Procedure section 580 both apply, found the record supported mistake/lack of notice, and directed amendment of the petition and an opportunity to answer.

The Georgia Court of Appeals dismissed an appeal filed by Demarcus Davis from a final divorce judgment entered January 6, 2026. The court held that appeals in domestic relations cases must be brought by application for discretionary appeal under OCGA § 5-6-35(a)(2). Davis filed only a notice of appeal and asked the court to treat it as a discretionary application, but the court found that compliance with the discretionary-appeal procedure is jurisdictional. Because Davis did not file the required application, the court granted Young Seon Jo’s motion to dismiss for lack of jurisdiction and dismissed the appeal.

The Twelfth District Court of Appeals vacated a juvenile-court order that had granted visitation rights to the paternal grandfather because the juvenile court in Madison County lacked subject-matter jurisdiction to decide a grandparent-visitation claim under R.C. 3109.11. The appellate court reviewed statutory text and Ohio Supreme Court precedent establishing that only the common pleas general division has jurisdiction under R.C. 3109.11 and that juvenile courts have only the powers expressly granted by statute. Because Madison County's juvenile division has not been granted the common-pleas division's powers, the visitation judgment was void and therefore vacated.

The Athens County Juvenile Court’s grant of permanent custody of two children to Athens County Children Services was affirmed on appeal. The children had been in agency custody for more than 12 of a consecutive 22-month period. The parents argued the award was against the manifest weight of the evidence and that the agency failed to make reasonable reunification efforts. The court held prior trial-court orders had already found reasonable efforts and that clear-and-convincing evidence supported that permanent custody served the children’s best interests given parental mental-health issues, unresolved interpersonal violence between the parents, the daughter’s refusal to reunify, and the children’s need for stability.

The First District Court of Appeals affirmed the trial court’s adoption of a magistrate’s decision modifying parenting time for the parties’ minor son C.K., and partially granting a contempt finding and awards. The court held that modification was in C.K.’s best interest based on evidence that he was triggered by mother and preferred to reside primarily with father; the court found father in contempt only for failing to pay child support, not for other alleged violations. The court also affirmed allocation of guardian ad litem fees (split roughly two-thirds to father) and a small $500 attorney-fee award to mother.

The First District Court of Appeals affirmed the juvenile court’s rulings awarding legal custody of J.L. to the maternal grandmother. The appeal arose from a custody petition filed by the grandmother after the child’s mother died and subsequent interim-custody orders. The appellate court found challenges to the interim emergency orders moot because the juvenile court later made a final custody determination. The court upheld the juvenile court’s finding that the father was an unsuitable parent based on abandonment and detriment to the child, and it affirmed denial of the father’s Civ.R. 60(B) motion for relief for failure to plead operative facts warranting relief.

The Ohio Court of Appeals affirmed a juvenile court’s October 30, 2025 judgment granting legal custody of two children, K.M.H. and D.J.L.H., to their maternal grandparents. The grandparents had filed motions for custody after longstanding involvement with the children; a magistrate heard evidence in 2021, issued a decision in 2024, and after a status hearing in 2025 issued a new decision adopted by the trial court. The appellate court held the juvenile court had subject-matter jurisdiction, found the October 30, 2025 order final and appealable, and concluded no plain error invalidated the custody award because the magistrate expressly found awarding custody to the mother would be detrimental and considered the children’s best interests.

The Ohio Court of Appeals affirmed the juvenile court’s grant of permanent custody of B.H. to the Montgomery County Department of Job and Family Services (MCCS). The child entered agency custody shortly after birth and, despite periods of compliance, Mother repeatedly relapsed into substance abuse, missed services, lost housing, and failed to maintain regular contact or visitation. The court found MCCS had custody for more than 12 of 22 consecutive months, made reasonable reunification efforts, and that permanent custody was in the child’s best interest given the need for a stable, legally secure placement with foster parents willing to adopt.