Opinion issued January 8, 2026.
In The
Court of Appeals For The
First District of Texas ———————————— NO. 01-25-00539-CV ——————————— IN THE INTEREST OF J.M.L.H., A CHILD
On Appeal from the 315th District Court Harris County, Texas Trial Court Case No. 2024-00721J
MEMORANDUM OPINION
In this accelerated appeal, Mother challenges the trial court’s order
terminating her parental rights to her child, J.M.L.H.1 Mother argues on appeal that
(1) the evidence is legally and factually insufficient to support the trial court’s
finding that the Department of Family and Protective Services (the Department)
1 We refer to the parties using pseudonyms. See TEX. R. APP. P. 9.8(b)(2). made reasonable efforts to return J.M.L.H. to Mother through a surrogate and
(2) the due process rights of Mother and one of J.M.L.H.’s potential fathers were
violated because the Department failed to search for or serve the potential father in
advance of trial. We affirm.
Background
This appeal concerns J.M.L.H., a child who was under two years old at the
time of trial.
A. J.M.L.H.’s Mother and Father
Mother has four children including J.M.L.H. J.M.L.H.’s three elder siblings
live with Mother’s aunt.
Mother has a history of mental illness, with diagnoses that include anxiety,
bipolar I disorder, mood disorder, depression, suicidal ideation, and psychosis, as
well as schizoaffective disorder and/or schizophrenia.2 Mother also has a history of
substance abuse, and her medical records indicate a possible relation between at
least some of her mental health and substance abuse issues. Mother has been
diagnosed as abusing cocaine and ecstasy.
Mother’s criminal history includes:
• An indictment in Georgia on two pending counts of cruelty to children in the first degree, stemming from charges that Mother left her four-year-old child in a hotel room without supervision and deprived the child of necessary
2 Mother testified that she has been diagnosed with schizoaffective disorder and not schizophrenia.
2 sustenance to the extent that the child was malnourished and the child’s health and well-being were jeopardized;3
• A conviction of misdemeanor terroristic threat with the intent to place the complainant in fear of imminent serious bodily injury;
• A felony charge of aggravated assault with a deadly weapon;
• A felony charge of assault on a police officer;
• A felony charge of retaliation;
• A felony charge of harassment of a public servant; and
• A felony charge of assault on a contracted employee of the Harris County Jail.
The Department caseworker assigned to the case testified at trial that Mother had
also threatened the caseworker on multiple occasions, accusing the caseworker of
having removed J.M.L.H. from Mother without cause. For example, Mother
“texted [the caseworker] a few times, stating that [the caseworker] was going to
lose [her] . . . job and [her] life.”
Mother believes that J.M.L.H.’s father could be one of four men, including
Alleged Father 1 and Alleged Father 2. The fourth man is a stranger who sexually
assaulted Mother.
3 Mother testified that she left the child in the hotel room alone for 14 hours, but had asked the hotel’s manager to keep an eye on the child. Mother also stated that the child had access to snacks and knew how to heat up food in the microwave.
3 The caseworker testified that, at the start of the Department’s investigation,
the only information the Department had regarding the identity of J.M.L.H.’s
father was the name of Alleged Father 1. In her search for Alleged Father 1, the
caseworker “called possible relatives,” searched the Georgia Department of
Corrections, spoke with the Georgia District 3 Attorney’s Office, and visited a
last-known location of Alleged Father 1. She was unable to make contact with
Alleged Father 1, and Alleged Father 1 did not make contact with the Department.
The caseworker spoke with Alleged Father 1’s ex-wife, but the ex-wife had not
spoken to Alleged Father 1 for about two years. J.M.L.H.’s guardian ad litem
testified that Alleged Father 1 had not responded to attempts to contact him, had
not visited J.M.L.H., had not made any provisions for J.M.L.H., and had not
inquired as to her well-being. Mother has twice denied that Alleged Father 1 is
J.M.L.H.’s father.
The caseworker testified that, shortly before trial, Mother had identified a
second potential father, Alleged Father 2.4 However, Mother had provided just
Alleged Father 2’s name and, though she said she would also provide a phone
number for him, did not provide the phone number. While Alleged Father 2’s name
is somewhat unique, the caseworker did not make any efforts to locate him based
just on his name. 4 Mother testified that she provided the name of Alleged Father 2 two weeks before trial.
4 B. J.M.L.H.’s Removal
The caseworker testified that the Department began its investigation when
J.M.L.H. was around two weeks old. Mother was living at a shelter called Mission
of Yahweh at the time, “experiencing some postpartum” depression, “using
substances such as methamphetamines,” and “behaving in a concerning way.”5 The
Department received a referral alleging neglectful supervision of two-week-old
J.M.L.H. by Mother. On the day of the referral, Mother stated that she could not
“have [J.M.L.H.] anymore” and that she wanted to “give the baby to her aunt in
Georgia.” Mother asked J.M.L.H. if she wanted to go to Georgia, and claimed that
J.M.L.H., who was too young to speak, had responded that she did not want to go
to Georgia. The Department’s Child Protective Services (CPS) division’s
investigation concluded that there was “reason to believe” at least one allegation of
neglectful supervision by Mother.
5 According to the Department, Mother’s concerning behavior included: (1) not cooperating with the Department’s investigation; (2) trying to hide J.M.L.H. from the Department, (3) behaving “in crisis”; (4) stating that she “wanted to go get raped by the father of [J.M.L.H.] again so that she [could] get pregnant by the white rapist white man outside”; (5) crying and yelling profanities while on the floor; (6) “stating that she needed to pray as she attempted to evade law enforcement”; (7) stating that she could “only deal with white policemen” and that her rights had been violated when, she claimed, “every race was sent except a white police officer”; and (8) stating that “there [was] nothing the law [could] do to her” because she had renounced her citizenship and J.M.L.H. “[did] not have a name or foot prints.”
5 C. Difficulties Communicating with Mother
The caseworker testified that, after J.M.L.H.’s removal, the caseworker had
difficulties communicating with Mother. Initially, Mother wanted to speak to the
Department only through Mother’s attorney. Later, Mother at times had no phone
service. Mother’s threats to the caseworker were another obstacle. And at some
point later, Mother was incarcerated for a couple of months.
J.M.L.H.’s guardian ad litem also testified that Mother had initially
requested that the guardian ad litem contact Mother only through Mother’s
attorney. More recently, however, the guardian ad litem had been able to visit
Mother at the county jail.
D. Mother’s Family Plan and Visitations
The Department prepared a “Family Plan” for Mother with the goal of
reunifying Mother and J.M.L.H. Among other things, the Family Plan required that
Mother maintain stable housing; verify her employment and income; maintain
contact with the Department; avoid criminal activity; and undergo a substance
abuse assessment, psychiatric evaluation, and psychological evaluation.
Mother had not completed any of the Family Plan requirements by the time
of her incarceration. The caseworker was unable to determine whether Mother
completed any of the Family Plan requirements subsequent to her incarceration.
Mother attended a substance abuse program but did not provide a certificate of
6 completion. Mother did not complete the substance abuse assessment. Mother
testified she had not completed the psychiatric evaluation or psychological
evaluation included in her Family Plan, but stated that she had received a
psychiatric evaluation in connection with J.M.L.H.’s removal. Similarly, while she
had not completed a parenting class as required by her Family Plan, she had
attended parenting classes in the past.
To the caseworker’s knowledge, Mother had not seen J.M.L.H. since
J.M.L.H. was removed from her care. The trial court suspended any visits in May
2024, stating: “Due to [Mother’s] behavior at the CPS office visit, the Court
suspends visitation . . . until such time when [Mother] demonstrates sobriety, is in
compliance with all recommendations from a mental health provider, and is
actively engaged in services with the Department.” (Emphasis in original.) The
caseworker’s understanding was that there had been no visitations because Mother
“showed up to a potential visit with J.M.L.H. and was able to bypass security
guards and get into a secured area,” where Mother “caused chaos by throwing
staplers and phones.” The caseworker testified that, after Mother’s visitations with
J.M.L.H. were suspended, Mother had made no efforts to try to keep in contact
with J.M.L.H. through the caseworker.
7 E. Mother’s Circumstances at Time of Trial
At the time of trial, Mother was still incarcerated. The caseworker had
visited Mother on a monthly basis in the Harris County Jail. At each visit, the
caseworker would ask Mother for the names of her family members. Up until the
last two of the caseworker’s monthly visits before trial, Mother refused to provide
those names. Up until that time, Mother had not always sought a relationship with
J.M.L.H.
In the two months prior to trial, Mother’s demeanor had “changed a lot.”
Mother stated that she had been taking her medications, and the caseworker could
“tell a difference” when speaking to Mother. Though not all of Mother’s
concerning behaviors were gone, the caseworker had seen improvement. Mother
had told the caseworker that Mother was going to complete in jail those of the
Family Plan’s requirements she could. Mother also for the first time shared the
names of family members. At the time of trial, the caseworker’s understanding was
that Mother might soon be moved from jail to a drug rehabilitation program.
According to the Department, at the time of trial, Mother had not been able
to demonstrate that she was employed and able to provide a safe and stable home
for J.M.L.H. The Department had concerns about Mother’s ability to address her
own psychological needs. Mother had not been able to demonstrate that she could
maintain her own mental health. Mother’s medical records demonstrated that,
8 during her incarceration, she had not always complied with her prescriptions for
medications, had tried to overdose on her medication,6 and had engaged in
self-harm.7 At the time of trial, the Department thus still had concerns regarding
Mother’s ability to care for J.M.L.H. physically, financially, and emotionally if the
two were reunited. As such, the Department’s concurrent goals at the time of trial
were for J.M.L.H. to be adopted by a relative or non-relative.
J.M.L.H.’s guardian ad litem testified at trial that Mother had been unable to
demonstrate that she was able to meet J.M.L.H.’s basic needs. Mother was unable
to rectify the conditions that led to J.M.L.H.’s removal, to earn an income or
otherwise provide financially for J.M.L.H., to provide stable housing for J.M.L.H.,
or to provide permanency for J.M.L.H. The guardian ad litem had concerns
regarding Mother’s drug use and criminal activity. The guardian ad litem favored
termination of Mother’s parental rights.
Mother’s hope at the time of trial was that J.M.L.H. could be placed in a
“healthy environment” with a relative or family friend. Mother had at times sought
to have a relationship with J.M.L.H. The Department remained open to J.M.L.H.’s
being adopted by a relative. A possible placement with Mother’s aunt had been
6 Mother testified that the incident referenced involved her snorting a medicine she was prescribed for seizures because she felt a seizure coming on. 7 The Department stated at trial that Mother “attempted to jump off the top bunk as recently as February 2025.”
9 rejected based on concerns regarding the aunt’s already having five or six children
in her home (including J.M.L.H.’s three siblings), lacking the financial means to
support an additional child, and lacking a support system. The Department was
investigating a possible placement with one of Mother’s sisters based on a
suggestion by Mother a few days before trial. However, while J.M.L.H.’s guardian
ad litem believed there was value in J.M.L.H.’s knowing her biological family, the
guardian ad litem did not believe there was value in exploring further the option of
a placement with Mother’s sister.
F. J.M.L.H.’s Circumstances at Time of Trial
At the time of trial, J.M.L.H. had been living with a foster mother—the same
foster mother with whom J.M.L.H. had been initially placed when she was
removed from Mother’s care—for about a year. The placement was Foster
Mother’s first. Foster Mother testified at trial that, while it is just she and J.M.L.H.
in her home, J.M.L.H.’s support system includes Foster’s Mother’s “strong
community of friends and family that are in [Foster Mother’s] life.” Foster
Mother’s mother, who visits frequently from out of state, is Department-approved
to stay with J.M.L.H. Foster Mother noted that J.M.L.H.’s teachers at the daycare
J.M.L.H. attends also love J.M.L.H.
Foster Mother described J.M.L.H. as follows:
She is . . . really starting to become independent. She enjoys being silly. She likes to make people laugh. She is also very affectionate. So,
10 when there is someone she has an attachment to, whether it’s a friend or family member, she loves to give them hugs and kisses. She likes to make animal sounds. She likes to run around in our yard and she is -- oh, and she loves reading books. So, we read books, like, all the time, about 20 minutes a day. It’s, like, one of her favorite things to do.
Foster Mother testified that she “would love to” adopt J.M.L.H. and “be her mom
forever.” Foster Mother would like to see J.M.L.H. “grow up to have a community
that loves her and friends and family” and to “have every opportunity to seek an
education to pursue her interests [and] follow her dreams.” Foster Mother was
confident that she could meet J.M.L.H.’s needs into the future.
When the Department caseworker first contacted Foster Mother after the
placement, Foster Mother was “very welcoming.” According to the caseworker, by
the time of trial, Foster Mother had bonded with J.M.L.H. and exhibited caregiving
skills. Foster Mother took J.M.L.H. to doctors’ appointments and stayed in contact
with the Department regarding J.M.L.H.’s care. Foster Mother also had a support
system.
Both the caseworker and J.M.L.H.’s guardian ad litem testified that Foster
Mother was meeting all of J.M.L.H.’s basic needs. J.M.L.H. was “well taken care
of” under Foster Mother’s care. Foster Mother provided J.M.L.H. a “drug-free”
and “safe and stable environment” in which J.M.L.H. has a routine and frequently
attends Department-approved daycare. Foster Mother provided J.M.L.H. with a
crib, highchair, and car seat. 11 J.M.L.H. has been with Foster Mother since she was two weeks old, and
Foster Mother’s home is the only home J.M.L.H. has known. J.M.L.H. was doing
“very well” and “thriving” with Foster Mother, and neither the Department nor the
guardian ad litem had any concerns about the placement. The guardian ad litem
recommended at trial that J.M.L.H. stay in her current placement. “Everything
appear[ed] to be going really well.” J.M.L.H. had a “healthy, strong bond” with
Foster Mother and was doing well in daycare. J.M.L.H. was developmentally on
target. J.M.L.H. was loved by everyone, was walking, and was advancing in her
milestones. J.M.L.H. was attached to Foster Mother and “fe[lt] loved” by Foster
Mother. The caseworker believed that J.M.L.H.’s staying with Foster Mother was
in J.M.L.H.’s best interest because J.M.L.H. was “taken care of,” “loved,” and
“supported.”
G. Mother’s Trial Testimony
Mother testified at trial that she loved J.M.L.H. and did not want her parental
rights terminated. She asked the trial court to leave J.M.L.H. with Foster Mother
for the time being, while Mother is in custody. But she asked the trial court not to
terminate her parental rights, and to permit the Department to explore Mother’s
sister and the man she believed to be J.M.L.H.’s father—Alleged Father 2, whose
name she had provided to the caseworker shortly before trial—as potential
caregivers to leave open the possibility that Mother could regain custody of
12 J.M.L.H. after the completion of her deferred adjudication program. Alleged
Father 2 currently lives in Louisiana, but has a townhome in Georgia.
Mother had begun to take her medicine more frequently, noting that she
previously “might have missed . . . eight months, ten days total.” Complying with
her medication has made Mother feel better. She testified that she was aware of
community resources that are available to help her with any future mental health
struggles, and knows to call 2-1-1 or a crisis hotline if necessary. Mother stated at
trial that she believed that, with the benefit of the parenting and substance abuse
classes she had taken, she is more equipped to respond to challenges than she was
previously.
Mother stated that she had been substance-free for two years. While in
custody, Mother had participated in a drug treatment program, but was removed
from that program after a 45-day period of sobriety. During the program, Mother
learned anger management, not to use drugs as a coping mechanism, and to avoid
individuals who use drugs. Mother noted that her felony charge of Aggravated
Assault with a Deadly Weapon occurred before she had learned about anger
management and coping skills. She now better understands her own behavior and
how to proceed moving forward. She stated that her behaviors have changed, as
well as her understanding of the severity of those behaviors.
13 Mother testified that she would like an opportunity to reunite with J.M.L.H.
Mother was working at a hair boutique—a type of work she had done previously.
Mother believed she could make enough money at the hair boutique to provide for
herself and J.M.L.H. Mother’s support system included her older sister, with whom
Mother had contact while in custody, and a woman who, at least for a time, served
as a foster mother for Mother’s other daughter.
Mother stated that, after she was released from custody, she planned to live
with J.M.L.H.’s father and his sister. He had been working a warehouse job for
three years, and Mother believed there would be enough space in the home for her
and J.M.L.H. Mother planned to enroll J.M.L.H. in daycare, and would also have
assistance from the support system she had mentioned.
H. Trial Court Judgment
On June 25, 2025, the trial court terminated Mother’s parental rights under
subsections 161.001(b)(1)(D), (E), (N), and (O) of the Texas Family Code, and
found that the termination of Mother’s parental rights was in J.M.L.H.’s best
interest under subsection 161.001(b)(2). Under section 161.002 of the Texas
Family Code, the trial court also terminated the parent-child relationship, “if any
exists,” between J.M.L.H. and Alleged Father 1 and between J.M.L.H. and
14 “respondent father unknown.” The “respondent father unknown” appears to have
been a reference to the stranger who sexually assaulted Mother.8
Sufficiency of the Evidence
The first of Mother’s two issues on appeal is her claim that there is legally
and factually insufficient evidence supporting the trial court’s finding under
subsection 161.001(b)(1)(N)(i) of the Family Code that the Department made
reasonable efforts to return J.M.L.H. to Mother.
A. Standard of Review
In a case to terminate parental rights under section 161.001 of the Texas
Family Code, the Department must establish that (1) the parent committed one or
more of the enumerated acts or omissions justifying termination and
(2) termination is in the best interest of the child. TEX. FAM. CODE § 161.001(b).
Only one predicate finding under subsection 161.001(b)(1) is necessary to support
a judgment of termination when there is also a finding that termination is in the
child’s best interest. In re A.V., 113 S.W.3d 355, 362 (Tex. 2003). The Department
must prove both elements—i.e., both the statutorily prescribed predicate finding(s)
and that termination is in the child’s best interest—by clear and convincing
evidence. In re E.N.C., 384 S.W.3d 796, 803 (Tex. 2012). The Family Code
8 The Department first sought the termination of the parental rights of an “unknown” father over a year before trial. Mother testified that she identified Alleged Father 2 as J.M.L.H.’s potential father two weeks before trial.
15 defines “clear and convincing evidence” as “the measure or degree of proof that
will produce in the mind of the trier of fact a firm belief or conviction as to the
truth of the allegations sought to be established.” TEX. FAM. CODE § 101.007.
When assessing the legal sufficiency of the evidence in a termination
proceeding, we consider all evidence in the light most favorable to the trial court’s
finding and decide “whether a reasonable trier of fact could have formed a firm
belief or conviction that its finding was true.” In re J.F.C., 96 S.W.3d 256, 266
(Tex. 2002); see also City of Keller v. Wilson, 168 S.W.3d 802, 817 (Tex. 2005)
(discussing elevated standard of review in parental termination cases). We assume
that any disputed facts were resolved in favor of the finding if a reasonable
factfinder could have done so. J.F.C., 96 S.W.3d at 266. When “no reasonable
factfinder could form a firm belief or conviction” that the matter on which the
Department bears the burden of proof is true, we “must conclude that the evidence
is legally insufficient.” Id. In reviewing the evidence’s factual sufficiency, we
consider the entire record, including disputed evidence. Id. The evidence is
factually insufficient if, considering the entire record, the disputed evidence that a
reasonable factfinder could not have resolved in favor of the finding is so
significant that the factfinder could not reasonably have formed a firm belief or
conviction. Id.
16 We give due deference to the factfinder’s findings, and we cannot substitute
our own judgment for that of the factfinder. See In re H.R.M., 209 S.W.3d 105, 108
(Tex. 2006) (per curiam). The factfinder is the sole arbiter when assessing the
credibility and demeanor of witnesses. See id. at 109.
B. Analysis
As noted above, only one predicate finding under subsection 161.001(b)(1)
is necessary to support a judgment of termination when there is also a finding that
termination is in the child’s best interest. A.V., 113 S.W.3d at 362. Because Mother
does not challenge the sufficiency of the evidence supporting the trial court’s
predicate findings under subsections 161.001(b)(1)(D), (E), and (O) of the Family
Code or the trial court’s finding that termination was in J.M.L.H.’s best interest,
we need not consider whether sufficient evidence supports the trial court’s finding
under subsection 161.001(b)(1)(N). See A.V., 113 S.W.3d at 362 (in appeal in
which appellant did not challenge trial court’s predicate finding under subsection
161.001(b)(1)(Q), holding that supreme court did not need to consider whether trial
court’s predicate finding under another subsection was supported by factually and
legally sufficient evidence for termination); Fletcher v. Dep’t of Family &
Protective Services, 277 S.W.3d 58, 64 (Tex. App.—Houston [1st Dist.] 2009, no
pet.) (in appeal in which appellant did not challenge trial court’s possible predicate
finding under subsection 161.001(b)(1)(N), holding that appellate court could not
17 consider “either the challenged grounds or the unchallenged ground and ha[d] no
choice but to overrule the challenges that the appellant ha[d] chosen to assert”); see
also In re A.B.-G., No. 01-24-00509-CV, 2024 WL 4982500, at *11–12 (Tex.
App.—Houston [1st Dist.] Dec. 5, 2024, pet. denied) (mem. op.) (holding that rule
requiring appellate court to review trial court’s predicate findings under
subsections 161.001(b)(1)(D) and (E) if challenged, even where another ground is
sufficient for termination, does not apply when findings under (D) and (E) are not
challenged).
We overrule Mother’s first issue.
Failure to Serve Alleged Father 2
The second of Mother’s two issues on appeal is her claim that the due
process rights of Mother and those of one of J.M.L.H.’s potential fathers—Alleged
Father 2—were violated because the Department failed to search for or serve
Alleged Father 2 in advance of trial. As noted above, Mother testified that she
identified Alleged Father 2 as a potential father of J.M.L.H. two weeks before trial.
Mother told the caseworker that Mother would provide his phone number, but then
failed to do so. The caseworker did not make any efforts to locate Alleged Father 2
based just on his name.
Mother argues that Alleged Father 2’s due process rights were violated, and
that “the trial court erred in rendering a termination order,” because the statutory
18 prerequisites for the termination of the rights of an alleged biological father were
not met as to Alleged Father 2. See TEX. FAM. CODE § 161.002. However, the trial
court’s judgment makes no reference to Alleged Father 2. While the trial court
terminated the parent-child relationship, “if any exists,” between J.M.L.H. and
“respondent father unknown,” Alleged Father 2 was not “unknown.” When Mother
first disclosed Alleged Father 2 as J.M.L.H.’s potential father, two weeks before
trial, she also disclosed his name. The Department had sought termination of the
parental rights of an “unknown” father—presumably the man who sexually
assaulted Mother—beginning over a year prior to trial. Moreover, even if the trial
court’s judgment could be read as terminating the parental rights of Alleged
Father 2, Mother does not have standing to challenge that termination. See In re
K.D.T., No. 14-22-00224-CV, 2022 WL 3093384, at *4 n.1 (Tex. App.—Houston
[14th Dist.] Aug. 4, 2022, pet. denied) (mem. op.) (holding that mother had no
standing to challenge termination of father’s parental rights).
Mother asserts that the “parents’” due process rights were violated because
the Department failed to search for or serve Alleged Father 2 in advance of trial.
While she uses the plural possessive, presumably to also reference her own due
process rights, she has not identified or briefed any alleged violation of her own
due process rights. The rules of appellate procedure contain specific requirements
for briefing, including briefing in appeals from final decrees terminating a parent’s
19 parental rights to their child. See TEX. R. APP. P. 38.1(f) (brief must state all issues
presented for review), (h) (brief must contain clear summary of arguments),
(i) (brief must contain clear argument for contentions made with appropriate
citations to authority and record); see also In re D.J.W., 394 S.W.3d 210, 223 (Tex.
App.—Houston [1st Dist.] 2012, pet. denied) (rejecting under rule 38.1(i) mother’s
challenge to legal and factual sufficiency of finding under section 161.001, noting
her brief contained no legal argument in support of those points); In re K.C.B., 280
S.W.3d 888, 896 (Tex. App.—Amarillo 2009, pet. denied) (rejecting under rule
38.1(i) mother’s challenge to finding under section 161.001, noting her brief
contained no analysis of relevant facts or law). To the extent Mother had a
complaint regarding an alleged violation of her own due process rights, she was
required, among other things, to state concisely her complaint, provide succinct
and clear argument for why her complaint has merit in fact and in law, and cite and
apply authorities applicable to the lodged complaint along with appropriate record
references. See TEX. R. APP. P. 38.1(f), (h), (i). By failing to adequately brief her
claim that her due process rights were violated by the Department’s failure to
search for or serve Alleged Father 2 in advance of trial, Mother has waived this
issue for appellate review. Even if this issue were properly before us, a party
generally lacks standing to assert a due process violation based on improper
service on another party. In re Guardianship of V.A., 390 S.W.3d 414, 418 (Tex.
20 App.—San Antonio 2012, pet. denied); see also Lemieux v. Harley, No.
02-24-00009-CV, 2024 WL 3282209, at *4 (Tex. App.—Fort Worth July 3, 2024,
no pet.) (mem. op.) (holding that guardian grandparents had no due process claim
based on alleged failure to properly serve citation on ward in guardianship case
that terminated their guardianship; reasoning that, while guardians may have been
aggrieved by decision, they were not personally prevented from appearing and
meaningfully participating in proceeding).
We thus overrule Mother’s second issue.
Conclusion
We affirm the trial court’s decree of termination.
Amparo “Amy” Guerra Justice
Panel consists of Justices Guerra, Caughey, and Dokupil.