In the Interest of E.A.R., E.A.R., E.A.R. and E.A.R., Children v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJune 21, 2023
Docket04-22-00800-CV
StatusPublished

This text of In the Interest of E.A.R., E.A.R., E.A.R. and E.A.R., Children v. the State of Texas (In the Interest of E.A.R., E.A.R., E.A.R. and E.A.R., Children v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Interest of E.A.R., E.A.R., E.A.R. and E.A.R., Children v. the State of Texas, (Tex. Ct. App. 2023).

Opinion

Fourth Court of Appeals San Antonio, Texas OPINION

No. 04-22-00800-CV

IN THE INTEREST OF E.A.R., E.A.R., E.A.R. and E.A.R.

From the 57th Judicial District Court, Bexar County, Texas Trial Court No. 2021-PA-00214 Honorable Linda A. Rodriguez, Judge Presiding

Opinion by: Liza A. Rodriguez, Justice

Sitting: Patricia O. Alvarez, Justice Liza A. Rodriguez, Justice Lori I. Valenzuela, Justice

Delivered and Filed: June 21, 2023

AFFIRMED

Mother and Father appeal from the trial court’s order terminating their parental rights. They

both argue the bench trial did not commence before the mandatory dismissal date prescribed by

section 263.401 of the Texas Family Code, making the termination order void. They also argue

the trial court’s termination order was signed after the date authorized by section 263.4011.

Additionally, Father argues (1) the evidence is legally and factually insufficient to support its

finding that termination of his rights was in his children’s best interest; and (2) the trial court

abused its discretion in making its conservatorship finding. We affirm. 04-22-00800-CV

MANDATORY DISMISSAL DATE

Section 263.401 requires a trial court presiding over a suit filed by the Department that

requests termination of the parent-child relationship to commence the trial on the merits within

one year after the initial temporary order. See TEX. FAM. CODE § 263.401. Under circumstances

enunciated in section 263.401(b), the trial court may extend the one-year deadline, or “dismissal

date.” See id. § 263.401. If the trial court does not commence trial by the dismissal date or extend

the dismissal date pursuant to subsection (b), the trial court’s jurisdiction over the suit “is

terminated and the suit is automatically dismissed.” Id. § 263.401(a).

Both Mother and Father argue on appeal that the trial court failed to commence the trial on

the merits by the mandatory dismissal date and thus lost jurisdiction over the termination suit. The

parties agree that the dismissal date in this case was August 6, 2022. The parties disagree about

whether the trial on the merits commenced before August 6, 2022. The record reflects that on

February 4, 2021, the Department of Family and Protective Services (“the Department”) filed its

original petition seeking termination of parental rights to eight-year-old Evelyn, six-year-old

Ethan, two-year-old Elijah, and one-year-old Eidan. 1 That same day, the trial court signed an

emergency order removing the children from the parents’ care and naming the Department as

temporary conservator. On December 1, 2021, the trial court extended the mandatory dismissal

date to August 6, 2022.

On July 20, 2022, the trial court held a hearing. It first considered Mother’s motion to

reconsider the trial court’s denial of her motion for monitored return of the children. After the trial

court denied Mother’s motion to reconsider, the parties and the trial court discussed the mandatory

1 To protect the identity of the minor children, we refer to the parties by fictitious names, initials, or aliases. See TEX. FAM. CODE § 109.002(d); TEX. R. APP. P. 9.8(b)(2). Because the children in this suit have the same initials, we refer to them by first names.

-2- 04-22-00800-CV

dismissal deadline of August 6, 2022. As a result of those discussions, the trial court decided to

proceed with the bench trial on the merits, which had been scheduled for that day. The Department

called the caseworker to the witness stand. The caseworker testified that she was the caseworker

assigned to the case and that the parents were Mother, Father (father to Elijah and Eidan), and two

other fathers (fathers to Evelyn and Ethan, respectively). 2 She testified that at the time of the

hearing, Evelyn was nine years old; Ethan was seven years old; Elijah was three years old; and

Eidan was two years old. She further testified (1) Evelyn was placed with her paternal

grandmother, (2) Elijah and Eidan were placed in a foster-adopt home, and (3) Ethan was placed

with a foster father. She testified those placements were meeting the children’s needs. The

Department then requested that the trial court continue the trial to a later date. The trial court

granted the request. On September 1, 2022, the trial continued. At the end of the day on September

2, 2022, the trial court continued the trial until October 13, 2022. After hearing testimony on

October 13, 2022, the trial court took the matter under advisement. On December 28, 2022, the

trial court signed the order terminating Mother’s and Father’s parental rights.

On appeal, Mother and Father argue that the trial on the merits did not “commence” on

July 20, 2022, because the Department did a “brief examination” of the witness with the intention

of “stopping the clock” on the mandatory dismissal date. They contend that the analysis of whether

a trial “commences” should focus “on what it means to commence a ‘trial’ or ‘final hearing,’ which

would require a more involved hearing in which both sides have an opportunity to examine a

witness, and the witness provides testimony that establishes at least one element of the offense(s)

being charged against the parent(s).” They cite no legal support for this assertion.

2 Evelyn’s and Ethan’s fathers have not appealed the trial court’s termination order.

-3- 04-22-00800-CV

This court has previously held that trial commenced for purposes of section 263.401 when

the Department called its first witness who then provided brief testimony before trial was recessed.

See In re R.F., No. 04-17-00582-CV, 2018 WL 1308542, at *1 (Tex. App.—San Antonio Mar. 14,

2018, no pet.). The record in this case clearly shows that the trial court began the trial on July 20,

2022, and the Department called its first witness who gave brief testimony. Thus, under our prior

precedent, trial commenced for purposes of section 263.401 before the mandatory dismissal date.

See id.

Nonetheless, Mother and Father argue that what occurred on July 20, 2022 should not be

considered as the commencement of trial because calling the caseworker to the stand to give brief

testimony was done for the sole purpose of avoiding the mandatory dismissal deadline. In In re

Z.S., 631 S.W.3d 313, 317 (Tex. App.—Houston [14th Dist.] 2020, no pet.), the Fourteenth Court

of Appeals considered this same argument. The appellant in that case argued the trial court did not

“commence” the trial before the mandatory dismissal date because the hearing held before the

dismissal date was a “‘sham,’ carried out with the ‘sole intent’ to retain the case on the court’s

docket beyond the automatic dismissal date.” Id. The court of appeals rejected this argument,

reasoning that whether the proceeding was a “sham” was an issue for the legislature and not the

court. Id. at 318. The court of appeals explained that section 263.401 “requires only that trial on

the merits ‘commence’ by the deadline, and here trial commenced before that deadline and before

the court lost jurisdiction.” Id. at 319. We agree with the Fourteenth Court of Appeals. In looking

at the plain language of section 263.401, the only issue for this court is whether the trial

commenced before the mandatory dismissal deadline. The record shows that it did.

Mother and Father further argue that even if this court determines that the trial commenced

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In the Interest of E.A.R., E.A.R., E.A.R. and E.A.R., Children v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-ear-ear-ear-and-ear-children-v-the-state-texapp-2023.