in the Interest of J.A.M., a Child

CourtCourt of Appeals of Texas
DecidedJune 30, 2011
Docket11-10-00333-CV
StatusPublished

This text of in the Interest of J.A.M., a Child (in the Interest of J.A.M., a Child) 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.

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in the Interest of J.A.M., a Child, (Tex. Ct. App. 2011).

Opinion

Opinion filed June 30, 2011

                                                                       In The

  Eleventh Court of Appeals

                                                                   __________

                                                         No. 11-10-00333-CV

                           IN THE INTEREST OF J.A.M., A CHILD

                                   On Appeal from the 266th District Court

                                                            Erath County, Texas

                                                   Trial Court Cause No. CV30303

                                            M E M O R A N D U M   O P I N I O N

            The trial court terminated appellant’s parental rights to her son, J.A.M.  J.A.M.’s father voluntarily relinquished his rights and is not a party to this appeal.  We affirm.[1]

On November 25, 2009, less than four months after J.A.M. was born, the Texas Department of Family and Protective Services filed an “Original Petition for Protection of a Child, for Conservatorship, and for Termination in Suit Affecting the Parent-Child Relationship.”  The trial court also signed an emergency protection order on that day.  The emergency removal was connected with drug usage by appellant and others who were around the child.

Pursuant to Tex. Fam. Code Ann. § 263.401(a) (Vernon 2008), the trial court established a dismissal date of November 29, 2010, and set a trial date of October 13, 2010.

Appellant was incarcerated when the trial court conducted a bench trial in this case on October 13, 2010.  Sometime prior to the hearing, appellant filed a “Motion for Extension” in which she asked the trial court to extend the dismissal date for a period of 180 days as provided for in Section 263.401(a).  She alleged that she anticipated that she would be completing her incarceration by then, that she could appear and testify at the final hearing about positive changes she had undergone, and that the extension would also give her time to better comply with the service plan provided by the Department.  There were no affidavits attached to the motion, and no evidence was ever offered in support of the motion, other than statements made by appellant’s attorney.

Appellant has brought two issues on appeal.  When we read the argument portion of appellant’s brief, we take it that in both issues she complains that she was deprived of due process.  First, she claims that she was deprived of due process when the trial court not only denied her the right to a bench warrant but also denied her motion for extension.  Appellant also makes the claim that she was deprived of her constitutional right to confront witnesses.  Next, she argues, among other things, that she was denied her due process rights when the trial court denied her motion for extension, thus preventing her from appearing in person and showing the positive changes that she had made.

At the outset, we note that this is a civil proceeding and that the constitutional right of confrontation is applicable to criminal proceedings.  See U.S. Const. amend. VI.  Furthermore, appellant has waived this portion of her complaint for failure to brief the issue as required by Tex. R. App. P. 38.1(i). 

Appellant makes the argument that the trial court erred when it did not issue a bench warrant.  While the trial court said that it thought the matter of a bench warrant had been brought up previously but that it was not going to issue one, the record does not show that appellant asked the trial court to issue one.  Nevertheless, even if she had asked the trial court to issue a bench warrant, the issue is not briefed as required by Rule 38.1(i) and is waived. 

But, even if the point is not waived, while litigants cannot be denied access to the courts simply because they are inmates, an inmate does not have an absolute right to appear in person in every court proceeding. See Hudson v. Palmer, 468 U.S. 517, 523 (1984); see also Zuniga v. Zuniga, 13 S.W.3d 798, 801 (Tex. App.—San Antonio 1999, no pet.).  In a termination suit, an incarcerated defendant has no absolute right to appear in person at the proceedings.  In re Z.L.T., 124 S.W.3d 163, 165-66 (Tex. 2003).

When deciding cases involving requests for the issuance of bench warrants, Texas courts of appeal follow the Seventh Circuit’s decision in Stone v. Morris, 546 F.2d 730, 735-36 (7th Cir. 1976).  There are various factors that trial courts should consider when deciding whether to grant an inmate’s request for a bench warrant.  These factors include the cost and inconvenience of transporting the prisoner to the courtroom; the security risk the prisoner presents to the court and public; whether the prisoner’s claims are substantial; whether the matter’s resolution can reasonably be delayed until the prisoner’s release; whether the prisoner can and will offer admissible, noncumulative testimony that cannot be effectively presented by deposition, telephone, or some other means; whether the prisoner’s presence is important in judging his demeanor and credibility; whether the trial is to the court or a jury; and the prisoner’s probability of success on the merits.  In re Z.L.T., 124 S.W.3d at 165-66.

If appellant wanted the trial court to issue a bench warrant, then the burden was upon her to bring forth factual information regarding those factors.  In re Z.L.T., 124 S.W.3d at 166.  Appellant’s presentation showed that the state jail in which she resided was less than 100 miles from the place of trial; that she was a female, non-violent drug offender; and that her claims were substantial.  But, as the trial court stated, based upon statements from appellant’s counsel, appellant could not be released from her incarceration until March 18, 2011, at the earliest, and, perhaps, as late as April 18, 2011.  Any extension that the trial court might grant could not be later than May 29, 2011.  The trial court reasoned that such a schedule would not allow “her time to do anything anyway.”

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Related

Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
Low v. Henry
221 S.W.3d 609 (Texas Supreme Court, 2007)
Zuniga v. Zuniga
13 S.W.3d 798 (Court of Appeals of Texas, 1999)
Hardy v. Marsh
170 S.W.3d 865 (Court of Appeals of Texas, 2005)
In the Interest of B.L.D.
113 S.W.3d 340 (Texas Supreme Court, 2003)
In the Interest of Z.L.T.
124 S.W.3d 163 (Texas Supreme Court, 2003)
In the Interest of D.M.
244 S.W.3d 397 (Court of Appeals of Texas, 2007)

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in the Interest of J.A.M., a Child, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-jam-a-child-texapp-2011.