in the Interest of C.R.P., a Child

Procedural entryThis page is a short order in in the Interest of C.R.P., a Child. Read the opinion of the Court — 2006 Tex. App. LEXIS 3035
Court of Appeals of Texas·Decided April 13, 2006·No. 02-05-00137-CV·Published

Opinion

                                      COURT OF APPEALS

                                       SECOND DISTRICT OF TEXAS

                                                   FORT WORTH

                                        NO. 2-05-137-CV

IN THE INTEREST OF C.R.P., A CHILD

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              FROM THE 271ST DISTRICT COURT OF WISE COUNTY

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                                             OPINION

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This is an appeal from the trial court=s dismissal of a petition to vacate the adoption of C.R.P.,[1] and in the alternative, original petition for suit affecting the parent-child relationship.  In three issues, Crystal and Larry assert that the trial court erroneously concluded that provisions in the family code barred Crystal=s suit to set aside the termination of her parental rights, that the bars to a suit attempting to set aside a termination judgment unconstitutionally infringe on a mother=s rights when she unknowingly and involuntarily surrendered her parental rights to the child in documents procured by subterfuge, and that the trial court erroneously concluded that Crystal and Larry lacked standing to file a suit affecting the parent-child relationship.  We affirm.

STATEMENT OF FACTS

Crystal is the daughter of Billy Ray and Rosmarie, and the biological mother of C.R.P.  Crystal was seventeen years old and living with her parents when she became pregnant with C.R.P.  On October 28, 1999, the trial court terminated Crystal=s parental rights because she had executed an unrevoked or irrevocable affidavit of relinquishment of parental rights to her child, C.R.P.  The trial court granted the adoption of C.R.P. to her maternal grandparents, Rosemarie and Billy Ray; Billy Ray is now deceased.  Subsequently, Crystal married Larry, who has no biological relation to C.R.P.

On September 7, 2004, Crystal and Larry filed a petition to vacate the adoption, and in the alternative, an original petition in a suit affecting the parent-child relationship and requesting a temporary restraining order.  Rosemarie filed a motion to dismiss, and the trial court dismissed the case.

STANDING


In their first issue, Crystal and Larry assert that the trial court erroneously concluded that several provisions in the family code bar the suit to set aside the termination of Crystal=s parental rights.  In their third issue, Crystal and Larry assert that the trial court erroneously concluded that Crystal and Larry lacked standing to file a suit affecting the parent-child relationship.

Standing is a question of law, and we review the issue de novo.  In re SSJ‑J, 153 S.W.3d 132, 134 (Tex. App.CSan Antonio 2004, no pet.).  As with an order of dismissal for lack of subject matter jurisdiction, we review an order of dismissal for lack of standing by construing the pleadings in favor of the plaintiff and must look to the pleader=s intent.  Tex. Ass=n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 446 (Tex. 1993).


The family code provides that the trial court may terminate a parent=s rights to a child if the parent executes an unrevoked or irrevocable affidavit of relinquishment of parental rights and the termination is in the child=s best interest.  Tex. Fam. Code Ann. ' 161.001(1)(K), (2) (Vernon Supp. 2005); see also id.  ' 161.103.  After a valid termination, the court may also provide for the child=s adoption.  Tex. Fam. Code Ann. ' 162.016 (Vernon 2002).  The validity of an order terminating a person=s parental rights under an affidavit of relinquishment of parental rights is not subject to collateral or direct attack after the sixth month after the date the order was signed.  Tex. Fam. Code Ann. ' 161.211(a).  A direct or collateral attack on an order terminating parental rights based on an unrevoked affidavit of relinquishment of parental rights is further limited to issues of fraud, coercion, or duress.  Tex. Fam. Code Ann. ' 161.211(c).  Additionally, the validity of an adoption order is not subject to attack after six months following the date the adoption order was signed.  Tex. Fam. Code Ann. ' 162.012(a).

Crystal contends that the affidavit was executed unknowingly and involuntarily, and thus, it was void, which amounts to an assertion of fraud, duress, or coercion.  Though the legislature has permitted such challenges to an affidavit of voluntary relinquishment of parental rights, the suit is nonetheless barred by the family code because her challenge to the affidavit began nearly five years following the termination of her parental rights, well beyond the statutory six-month limitation.  See Tex. Fam. Code Ann

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