CPS = Child Protective Services; cases now litigated in name of Texas Department of Family &
Protective Services (
TDFPS or Texas DFPS); Also see --> Austin DFPS cases (Third Court of
Appeals) Appeals from Texas DFPS suits seeking termination of parental rights (Austin, TX)
Terminology: child abuse, child neglect | best interest of child | parenting skills | parenting plan |
drugs use |
best interest factors | parenting plan | relinquishment | appointment of sole managing
conservator (SMC). Other type of termination: -->
Termination of employment

RECENT APPELLATE CASES
(IN REVERSE CHRONOLOGICAL ORDER OF OPINION RELEASE DATE

In Interest of JSG, NO. 14-08-00754-CV (Tex.App.- Houston May 7, 2009)(Hedges)
(
termination of parental rights, best interest factors, natural parent preference, parental
presumption)
AFFIRMED: Opinion by Chief Justice Hedges  
Before Chief Justice Hedges, Justices Anderson and Seymore
14-08-00754-CV In the Interest of J.S.G., and J.A.G
Appeal from 314th District Court of Harris County
Trial Court Judge: John Phillips  

In Interest of RCR (Tex.App. – Houston [14th Dist.] Apr. 14, 2009)(Hedges)  
(
termination of parental rights, constitutional issue waived, frivolousness)
AFFIRMED: Opinion by
Chief Justice Hedges   
Before Chief Justice Hedges, Justices Anderson and Seymore
14-08-00904-CV In the Interest of R.C.R., Jr., A Child  
Appeal from County Court at Law of Washington County
Trial Court Judge: Matthew Alfred Reue

Quiroz v. DFPS (Tex.App.- Houston [1st Dist.] Apr. 9, 2009)(Alcala)(involuntary termination of
parental rights)
AFFIRM TC JUDGMENT: Opinion by Justice Alcala  
Before Justice Alcala
01-08-00548-CV Alejandra Quiroz v. Department of Family and Protective Services
Appeal from 314th District Court of Harris County
Trial Court Judge: Hon. John Phillips  

In the Interest of SN, SMN, DAN (Tex. App. – Houston [14th Dist.] Mar. 5, 2009)(Yates)
(termination)
AFFIRMED: Opinion by Justice Brock Yates  
Before Justices Brock Yates, Anderson and Brown
14-07-00161-CV In the Interest of S.N., S.M.N., and D.A.N., Children
Appeal from 314th District Court of Harris County
Trial Court Judge: John Phillips  

Crowden v. DFPS (Tex.App.- Houston [1st Dist.] Jan. 29, 2009)(Radack) (termination of parental
rights, jury trial) AFFIRM TC JUDGMENT: Opinion by Chief Justice Radack  
Before Chief Justice Radack, Justices Nuchia and Higley
01-07-00025-CV Michelle Haufrect Crowden v. Department of Family and Protective Services
Appeal from 328th District Court of Fort Bend County
Trial Court Judge: Hon. Ronald R. Pope  

Fletcher v. DFPS (Tex.App.- Housotn [1st Dist.] Jan. 8, 2009)(Radack) (termination of parental
rights)
AFFIRM TC JUDGMENT: Opinion by
Chief Justice Radack  
(Before Chief Justice Radack, Justices Nuchia and Higley
01-08-00052-CV        C.Y. Fletcher v. Department of Family and Protective Services
Appeal from 328th District Court of Fort Bend County
Trial Court Judge: Hon. Ronald Pope

ALSO SEE --->  2008 APPEALS IN TERMINATION OF PARENTAL RIGHTS / CPS
CASES
CPS and Termination of Parental Rights Cases
from Houston Courts of Appeals
Also see ---> Other Family Law Cases from Houston
Texas Supreme Court
Termination Appeals
(Tex. 2006-09)
The Texas Family Code requires that a
statement of points on which a party intends
to appeal be presented to the trial court
within fifteen days after the signing of a final
order terminating parental rights.
Tex. Fam.
Code § 263.405 (b). The Code further provides
that an appellate court is to consider only those
issues presented to the trial court in a timely filed
statement of points. Id. §
263.405(i). The issue in this parental rights
termination case is whether the failure to follow
these procedural rules in the Family Code
precludes appellate review of an ineffective
assistance of counsel claim.
In Interest of JOA, No.
08-0379 (Tex. May 1, 2009)(Medina)(termination of
parental rights appeal, constitutionality of
statement of points requirement for appeal)
IN THE INTEREST OF J.O.A., T.J.A.M., T.J.M., AND
C.T.M., CHILDREN; from Collingsworth County; 7th
district (07-07-00042-CV, 262 SW3d 7, 02-25-08)  
The Court modifies the court of appeals' judgment,
affirms the judgment as modified, and remands the
case to the trial court.
Justice Medina delivered the opinion of the Court.
Justice Willett delivered a concurring opinion.

Supreme Court says that omission of
statement of points from appellate record was
not appellant's fault and that court of appeals
should have reviewed the merits of the
mother's appeal from the trial court's order
terminating her parental rights.
In Interest of K.C.B., a Child, No. 07-1068 (Tex.
Apr. 18, 2008) (per curiam) (
parents right to
appeal in termination of parental rights case,
procedural requisites for appeal)

Supreme Court agrees with Houston Court of
Appeals that reversal of conservatorship to
CPS along with termination order was proper
in the absence of independent grounds to
take children from parent
In the Interest of DNC No. 07-0621 (Tex.
2008)(child protection, DFPS suit, termination of
parental rights, natural parent presumption, award
to conservatorship to child protection agency
reversed along with termination of parental rights)
N THE INTEREST OF D.N.C., A CHILD; from Harris
County; 1st district (01-04-01232-CV,
227 S.W.3d 799, 12/21/06)

In Interest of J.A.J., No. 07-0511 (Tex. Nov. 2,
2007)(O'Neill)(termination of parental rights,
conservatorship to CPS not appealed)

In Interest of R.R. and S.J.S., No. 06-0460 (Tex.
Dec. 1, 2006)(per curiam)(termination of parental
rights)

In re H.R.M., 209 S.W.3d 105 (Tex. 2006)
In Interest of H.R.M., No. 06-0270 (Tex. Dec. 1
2006)(per curiam)(termination of parental rights)

Opinion on Remand to the Fourteenth Court
of Appeals  
In the Interest of H.R.M. (Tex.App.-
Houston [14th Dist.] Mar. 8, 2007)(Justice Seymore)
This case is on remand from the Texas Supreme
Court for consideration of a single issue.  The
issue is whether the evidence is factually sufficient
to support the jury's finding that the parental rights
of William Keith M. ["Keith"] to his biological
daughter, H.R.M., should be terminated under
Texas Family Code Section 161.001(1)(Q), which
provides "parental rights may be terminated if the
parent has "knowingly engaged in criminal conduct
that has resulted in the parent's:  (i) conviction of
an offense; and (ii) confinement or imprisonment
and inability to care for the child for not less than
two years from the date of filing the petition."See In
re H.R.M., 209 S.W.3d 105, 107 (Tex. 2006) (per
curiam) (quoting Tex. Fam. Code Ann. Section
161.001(1)(Q))
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