In the Interest of E.K.H., a Child v. the State of Texas

CourtCourt of Appeals of Texas
DecidedNovember 19, 2024
Docket07-24-00191-CV
StatusPublished

This text of In the Interest of E.K.H., a Child v. the State of Texas (In the Interest of E.K.H., a Child 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.K.H., a Child v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-24-00191-CV

IN THE INTEREST OF E.K.H., A CHILD

On Appeal from 223rd District Court Gray County, Texas Trial Court No. 40,778, Honorable Jack Graham, Presiding

November 19, 2024 MEMORANDUM OPINION Before QUINN, C.J., and DOSS and YARBROUGH, JJ.

This appeal concerns the designation of conservatorship rights to a child, E.K.H.1

Though the Texas Department of Family and Protective Services initially sought

termination of Mother’s and Father’s parental rights, the case evolved into a

conservatorship dispute. After final hearing, the trial court appointed Father as E.K.H.’s

managing conservator and Mother as possessory conservator. In her sole issue on

appeal, Mother argues the trial court abused its discretion, contending the evidence failed

1 To protect E.K.H.’s privacy, we will refer to K.R. as “Mother,” N.H. as “Father,” and the child, E.K.H.,

by initials. See TEX. FAM. CODE ANN. § 109.002(d); TEX. R. APP. P. 9.8(b). to overcome the statutory presumption favoring joint managing conservatorship. We

disagree and affirm.

Background

This case began in December 2022, when the Department received a report of

neglectful supervision of E.K.H., who was one year old at the time. The report alleged

that Mother had been incarcerated on charges of aggravated assault with a deadly

weapon, theft, and child endangerment, and had left the child in another’s care. That

other caretaker, per the report, allegedly consumed alcohol, and marijuana in the child’s

presence.

This was far from Mother’s first involvement with the Department. The evidence

showed that between 2015 and 2022, the Department conducted seven investigations

concerning the adequacy of Mother’s care of her children. Most notably, in December

2017, both Mother and her newborn infant tested positive for methamphetamine. In

December 2020, Mother’s hair follicle test revealed amphetamines, MDMA/Ecstasy,

cocaine, and cocaine metabolites, leading to her children’s removal and placement with

their father. Then in April 2022, while caring for E.K.H., Mother was arrested for child

endangerment after law enforcement found the child’s car seat “turned over.” Rather than

complete court-ordered services, however, Mother left the state. Mother’s criminal history

during the eight-year period before the present investigation involved multiple theft

charges, probation violations, drug possession, and violent offenses, culminating in the

aggravated assault charges that led to her eighteen-month incarceration beginning in

December 2022.

2 The Department filed its petition to terminate parental rights in December 2022;

E.K.H. was removed and the Department appointed her temporary sole managing

conservator. At a January 2023 hearing, the trial court appointed both parents as

possessory conservators with limited rights and ordered them to complete services. Over

the next several months, Mother remained incarcerated, preventing her from having

contact with E.K.H. Father, meanwhile, complied with his service plan and progressed

from supervised visits to having E.K.H. placed in his home in July 2023.

According to permanency specialist Courtney Brown, E.K.H. was “doing very well”

in his care. Brown testified that Father and E.K.H. had developed “very much a healthy

parent/child relationship.” Though Brown acknowledged Father had a history of domestic

violence allegations involving his other children, she had witnessed no abuse toward

E.K.H. or Father’s live-in girlfriend. When the Department investigated one report about

Father’s physical discipline of E.K.H., it ultimately ruled out any abuse.

Mother was released from her 18-month incarceration in March 2024,

approximately six weeks before final hearing. There was evidence at final hearing that

Mother completed all services available to her while incarcerated. During those six

weeks, Mother secured housing with her boyfriend (who is father to one of her children,

but has a pending felony charge), obtained employment at an Amarillo hotel, began

counseling, and participated in a domestic violence support group. Her weekly

supervised visits with E.K.H. proceeded without incident, and both Brown and visitation

supervisor Treesen Pierson noted no concerns. Brown testified she saw no reason why

E.K.H. could not eventually be raised by both parents. However, given Mother’s recent

3 release from prison, Brown testified she would first like to see Mother demonstrate more

stability before being considered for joint managing conservatorship.

The Department recommended Father be named primary managing conservator

and Mother possessory conservator with a stair-stepped visitation schedule. Both the

guardian ad litem and CASA representative agreed, emphasizing E.K.H.’s stability in

Father’s care. The trial court signed an order consistent with these recommendations,

appointing Father as permanent managing conservator and Mother as possessory

conservator. The order established a step-up visitation schedule leading to Mother

potentially obtaining standard possession by July 2024. The court found that “the

circumstances of [E.K.H.], conservators or other party affected by the prior orders for

conservatorship in this case have materially and substantially changed since rendition of

the prior order, and that the appointment of [Father] as the sole managing conservator

would be a positive improvement for the child.”

Analysis

A trial court may appoint either a sole managing conservator or joint managing

conservators. TEX. FAM. CODE ANN. § 153.005(a). The child’s best interest is a trial court’s

primary consideration in determining issues of conservatorship and possession. Id.

§ 153.002. The law presumes that appointing parents as joint managing conservators

serves the child’s best interest, but this presumption is rebuttable. Id. § 153.131(b). We

review conservatorship determinations for an abuse of discretion, meaning we will

reverse only if the decision is arbitrary and unreasonable. In re J.A.J., 243 S.W.3d 611,

616 (Tex. 2007). In conducting this review, we consider whether the trial court had

4 sufficient evidence2 to exercise its discretion and whether it erred in applying that

discretion. In re L.T., No. 07-24-00002-CV, 2024 Tex. App. LEXIS 2986, at *6–7 (Tex.

App.—Amarillo Apr. 30, 2024, no pet.) (mem. op.).

Through a single issue, Mother argues the trial court abused its discretion in

appointing Father sole managing conservator rather than naming both parents joint

managing conservators as presumptively favored by statute. Specifically, Mother argues

there exists no material and substantial change of circumstances since the signing of a

prior final order because no earlier order appears in the record. However, there is no final

conservatorship order to modify because the order now on appeal is the only final

conservatorship determination for E.K.H. and Mother and Father. Cf. Crapps v. Crapps,

No. 12,478, 1976 Tex. App. LEXIS 3467, at *4 (Tex. Civ. App.—Austin Dec. 22, 1976, no

writ) (not designated for publication) (modification requires a prior final order, not

temporary orders).

Mother further contends there exists no evidence showing that Father’s

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Related

In the Interest of J.A.J.
243 S.W.3d 611 (Texas Supreme Court, 2007)

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