In the Interest of J. L., a Child v. the State of Texas

Court of Appeals of Texas·Decided April 24, 2025·No. 13-24-00068-CV·Published

Opinion

NUMBER 13-24-00068-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS CORPUS CHRISTI – EDINBURG

IN THE INTEREST OF J.L., A CHILD

ON APPEAL FROM THE 146TH DISTRICT COURT OF BELL COUNTY, TEXAS

MEMORANDUM OPINION

Before Chief Justice Tijerina and Justices West and Cron Memorandum Opinion by Chief Justice Tijerina

By four issues, appellant Father appeals the trial court’s order modifying the parent child relationship. 1 Father contends that (1) the trial court abused its discretion by increasing the amount of child support and the payment for the cost of Child’s health insurance; (2) the trial court deprived Father “of his Constitutionally protected liberty interest in his care, possession and management of [Child] because of [Father’s] indigence, in violation of Due Process and Fundamental Fairness guarantees of the

1 We use pseudonyms to protect the identity of the child. See TEX. FAM. CODE ANN. § 109.002(d).

Fourteenth Amendment”; (3) the trial court abused its discretion “by focusing on punishing [Father] for his initial failure to submit to a drug test entered without notice of hearing to him, rather than base the orders for possession and access upon [Child’s] best interests”; and (4) in the alternative, we should reform the judgment. We affirm in part and reverse and remand in part.2 I. BACKGROUND

On June 24, 2020, the trial court appointed appellee Mother and Father joint managing conservators of Child with Mother having the right to establish the primary residence of Child (original order). Father was awarded standard possession pursuant to the family code. The trial court ordered Father to pay $349 per month in child support, but he was not ordered to pay any amount for Child’s health insurance.

On August 3, 2020, Mother filed a petition to modify the original order alleging that “[t]he circumstances of [C]hild, a conservator, or other party affected by the order to be modified have materially and substantially changed since the date of rendition of the order to be modified.” Mother claimed that she had “information that [Father was] using illegal drugs” and requested that the trial court order Father to submit to fingernail drug testing. Mother further asked that Father’s visits with Child be supervised if Father “fail[ed], refus[ed], or alter[ed] the nail drug test.”

On August 5, 2020, the trial court granted Mother’s motion for drug screening and ordered Father to submit to a spontaneous supervised urine analysis and a nail drug test. The order stated, “If [Father] tests positive for a controlled substance or fails to comply

2 This case is before this Court on transfer from the Third Court of Appeals in Austin pursuant to a docket-equalization order issued by the Supreme Court of Texas. See TEX. GOV’T CODE ANN. § 73.001.

with the terms of this order when requested to submit to a drug screening, all periods of possession by [Father] shall be discontinued until further order of the Court.”

On July 8, 2021, Father filed a counterpetition to modify the original order alleging that “[t]he circumstances of [C]hild, a conservator, or other party affected by the order to be modified have materially and substantially changed since the date of the rendition of the order to be modified.” Father stated the following:

[Father] should be appointed the conservator with the exclusive right to determine [Child’s] residence, the exclusive right to receive and give receipt for periodic payments for the support of [Child] and to hold and disburse the funds [for] the benefit of the [Child], and the exclusive right to make educational decisions. [Father] requests all other rights be exercised independently. [Father] requests that [Mother] be given a possession under a standard possession order.

On March 13, 2023, Father filed a motion for temporary restraining order, temporary injunction and temporary orders requesting that the trial court restrain Mother from withdrawing Child from his current school without Father’s consent and requesting possession of Child. Father asked the trial court to order Mother not to allow Child to have any contact with a certain minor family member, Todd. Father alleged in another pleading that Child told him that Todd had sexually abused Child. On March 29, 2023, the trial court held a hearing on Father’s petition to modify and for temporary orders, and after a hearing, it denied Father’s motion and made a temporary order that Mother “continues to have primary, [Father] has continued [possession] rights per prior orders,” and Child would “remain in school and speech therapy.”3

3 Mother presented evidence at this hearing that the police investigation concerning Father’s

allegations had been closed “as unfounded,” and a caseworker for the Department of Family and Protective Services (CPS) testified that due to his disability, Child was unable to speak to her, the sexual abuse nurse examiner, or the forensic interviewer. The caseworker stated that although she attempted several times, she was unable to contact Father regarding the allegations. The caseworker testified that the case was closed due to a “conclusion of no findings” because Child “did not articulate, did not give a consistent

On April 4, 2023, Mother filed a counterpetition to modify the original order to increase child support due to a material and substantial change in circumstances. Mother alleged that Father “has a history of abusing controlled substances” and requested that the trial court order Father “to submit to a 10-panel fingernail and hair follicle drug test.” Mother requested “temporary orders for the safety and welfare of [Child], including, but not limited to” giving Mother “the exclusive right to apply and control the child’s passport” and ordering that Father “provide guideline child support . . . including . . . medical and dental support in the manner specified by the [trial c]ourt, while the case is pending.”

On April 25, 2023, the trial court held a hearing wherein Father failed to appear.

The trial court granted Mother’s motion for drug testing and ordered Father to “immediately submit to a spontaneous 10-Panel Nail Drug Test at Any Lab Test.” The order states:

If [Father] tests negative on the supervised 10-Panel Nail Drug Test, he shall immediately resume his possession and access schedule until further order of the Court.

If [Father] tests positive for a controlled substance or fails to comply with the terms of this order when requested to submit to a drug screening, all periods of possession by [Father] shall be discontinued until further order of the Court.

Father did not report for drug testing and filed a motion to set aside the trial court’s drug screening order claiming he did not appear at the hearing because he did not receive

outcry,” and did not outcry during the forensic interview. Finally, the caseworker said that after reviewing a video that Father recorded of Child making the allegations, “there were concerns for leading questions during that interview.” The caseworker testified that the school personnel informed her that Child “is in a special needs or more relatively ratio-lower classroom” and they had reported that another child in that class also named Todd had assaulted Child. The caseworker explained that the teacher believed there has been a “miscommunication” because “it was hard to kind of pull out of [Child] what the concerns are or what actually happened. . . .”

notice. The trial court held a hearing on Father’s motion and denied it.

On September 12, 2023, the trial court held a hearing on Father’s motion to modify the original order, and it “continue[d] to require [Father] to submit to drug test as previously ordered with no visitation until a neg[ative] test is obtained.” Father failed to take the ordered drug tests.

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In the Interest of J. L., a Child v. the State of Texas, (Tex. Ct. App. 2025).

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