In the Interest of E.H. and K.H., Children v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJanuary 23, 2025
Docket07-24-00295-CV
StatusPublished

This text of In the Interest of E.H. and K.H., Children v. the State of Texas (In the Interest of E.H. and K.H., 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.H. and K.H., Children v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-24-00295-CV

IN THE INTEREST OF E.H. AND K.H., CHILDREN

On Appeal from the 106th District Court Lynn County, Texas Trial Court No. 22-03-07825, Honorable Reed A. Filley, Presiding

January 23, 2025 MEMORANDUM OPINION Before QUINN, C.J., and PARKER and DOSS, JJ.

Pending before us is the appeal of the father of children EH and KH from the

underlying court’s order terminating his parental rights to his children. 1 His court-

appointed attorney filed a motion to withdraw supported by an Anders 2 brief. Through

the latter, counsel represented that the appeal was frivolous. We affirm.

1 Mother is not a party to this appeal.

2 Anders v. California, 386 U.S. 738, 87 S. Ct. 1396, 18 L. Ed. 2d 493 (1967). Background

The Department first became involved with the family after an allegation of

domestic violence during which both young children, EH and KH, were present. Father’s

girlfriend, Beth, and father had moved in together soon after meeting online. The

altercation in question consisted of an argument during which father threw a marijuana

bong at Beth.

Two months later, in March 2022, the Department was again contacted. KH, then

aged two, had been taken to the hospital with severe injuries. They included a skull

fracture coupled with significant bruising on his body and head. It occurred while father

was working and the children were in the care of Beth. Father testified at the final hearing

that “[m]y first initial thoughts when I first saw [KH] was that Beth had snapped and beat

him.” Though also having questions about her culpability, he further said “[s]he does

have tendencies to snap and it’s a way more higher possibility that she had caused the

injuries.”

In turn, Beth initially said she found KH and lacked knowledge how the injuries

occurred. Later, she told father that KH fell off a bed. Eventually, she represented that

father inflicted KH’s injuries. However, law enforcement interviewed her and observed

bruising on her hand. She also admitted to striking the child in the mouth after the child

cursed at her. Eventually, she was arrested for and charged with injury to a child. Shortly

thereafter, father and Beth married after her release from jail on bond and despite the

pending charges related to hurting his son. Trial upon the charge remained pending at

the time of the final termination hearing.

2 The Department removed the children from the home once the hospital determined

the injuries were not accidental. Father was given a service plan that included actions he

was to take to secure return of the children. The plan was developed to address drug

use, domestic violence, violence against children, and stability. Father completed some

but not all aspects of the plan. The trial court also heard testimony that father failed to

apply the lessons learned in the several programs he did complete. Other evidence

revealed that he 1) continued to test positive for use of controlled substances, 2) failed to

attend the requisite number of NA/AA meetings, 3) underwent arrest for domestic violence

against Beth, 4) failed to maintain a stable home, and 5) suffered eviction at one point.

Beth also testified at trial about various violent acts committed by father. They

included: 1) his choking her; 2) his carrying one child “to the room with just [child’s] arm”;

3) his “spank[ing] [the child] extremely hard to where he left bruises on him”; 4) his

“slamming” the faces of the kids against the wall “[w]henever the boys sometimes would

be in time out [and] . . . weren’t looking at the wall”; and 5) his “hit[ting] them up side the

head with his fist” for like reason. At time of the final hearing, father also had charges

pending against him for domestic violence. Those were not the sole accusation of family

violence levied against him. Evidence illustrated that he had previously been convicted

of engaging in like criminal conduct.

Discussion

As observed by our Texas Supreme Court, appointed “[c]ounsel’s obligation to the

client may . . . be satisfied by filing an appellate brief meeting the standards set in Anders

v. California, [386 U.S. 738 (1967)] and its progeny.” In re P.M., 520 S.W.3d 24, 27 (Tex.

2016). Utilizing Anders should be rare, given the plethora of actual issues normally

3 involved in a proceeding. In effect and when properly executed, the Anders process is

an exhaustive endeavor, Davis v. State, 683 S.W.3d 828, 830 (Tex. App.—Amarillo 2023)

(order), and must be treated as such by appointed counsel. Indeed, counsel’s analysis

should begin with the premise that if there were issues worth trying, there are probably

issues worth appealing. Id. And, only when a diligent search of the entire record by

counsel uncovers merely frivolous issues should the Anders procedure be utilized.

Next, issues are frivolous or lack merit when they have no basis in law or fact,

when they “‘cannot conceivably persuade the court.’” Id. (quoting Bowen v. State, No.

05-21-00845-CR, 2023 Tex. App. LEXIS 7249, at *1 n.2 (Tex. App.—Dallas Sep. 15,

2023, no pet.) (mem. op. on reh’g, not designated for publication)). So, appellate

counsel’s duty consists of urging the arguable, irrespective of the likelihood of success.

Id. Proper Anders analysis obligates counsel to explain how case law and the appellate

record foreclose potential issues. Id. That necessarily includes explanation, proper

citation to the record, and the application of pertinent legal authority.

But, counsel does not have the sole burden to peruse the record for arguable

issues. That task falls upon the reviewing court, as well. It must conduct an independent

analysis of the record and pertinent legal authority to determine if any potential error has

basis in law or fact. 3 See In re Schulman, 252 S.W.3d 403, 409 (Tex. Crim. App. 2008)

(noting the court’s obligation to conduct such examination).

As alluded to earlier, counsel filed an Anders brief, representing that “[a]fter a

diligent review of the record and the legal standards applicable to the case, [she] believes

3 Contrary to appellate counsel’s insinuation to appellant in a letter, the reviewing court, not its “staff

attorneys,” determines the frivolity of the appeal.

4 that the trial court correctly ruled on all objections raised during the trial and that no

reversible error was presented.”4 So too did counsel indicate she 1) provided a copy of

the Anders brief and appellate record to father and 2) explained to him his right to file a

pro se brief. Apparently, her initial effort to provide the record and Anders brief via

certified mail proved fruitless for the mailing was returned as “refused.” Counsel then

attempted a second mailing via regular mail. Our records do not reveal whether it was

refused or otherwise returned. This, however, is not true of this court’s separate

notification to father of his right to file a response to counsel’s Anders brief. It was

returned with the notation “return to sender not at this address.” We believe the address

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Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)
In Re Schulman
252 S.W.3d 403 (Court of Criminal Appeals of Texas, 2008)
in the Interest of P.M., a Child
520 S.W.3d 24 (Texas Supreme Court, 2016)
in Re Interest of N.G., a Child
577 S.W.3d 230 (Texas Supreme Court, 2019)
Office of Attorney General of Texas v. Burton
369 S.W.3d 173 (Texas Supreme Court, 2012)

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