in the Interest of L.I.C.S., a Child

CourtCourt of Appeals of Texas
DecidedMarch 16, 2022
Docket04-21-00287-CV
StatusPublished

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Bluebook
in the Interest of L.I.C.S., a Child, (Tex. Ct. App. 2022).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-21-00287-CV

IN THE INTEREST OF L.I.C.S., a Child

From the 73rd Judicial District Court, Bexar County, Texas Trial Court No. 2020PA01026 Honorable Susan D. Reed, Judge Presiding 1

Opinion by: Luz Elena D. Chapa, Justice

Sitting: Rebeca C. Martinez, Chief Justice Luz Elena D. Chapa, Justice Lori I. Valenzuela, Justice

Delivered and Filed: March 16, 2022

AFFIRMED

This is an accelerated appeal from an order terminating appellant L.S.’s parental rights to

her child, L.I.C.S. 2 On appeal, L.S. challenges the trial court’s jurisdiction and the sufficiency of

the evidence supporting the trial court’s findings as to grounds and best interest. We affirm the

trial court’s order of termination.

BACKGROUND

On May 21, 2020, the Texas Department of Family and Protective Services filed an original

petition seeking temporary managing conservatorship of L.I.C.S. and termination of L.S.’s

1 The Honorable David Canales is the presiding judge of the 73rd Judicial District Court. The Honorable Susan Reed, sitting by assignment, signed the order of termination. 2 To protect the identities of the minor child in this appeal, we refer to the parent and child by their initials. See TEX. FAM. CODE ANN. § 109.002(d); TEX. R. APP. P. 9.8(b)(2). 04-21-00287-CV

parental rights. 3 The affidavit in support of the petition stated at the time of removal, L.S., along

with her two children L.I.C.S. and S.S., 4 lived with L.S.’s mother, Connie, and Connie’s husband,

Felipe. According to the affidavit, L.S. would leave her children with Connie and Felipe to go do

drugs, specifically methamphetamine. On occasion, L.S. would take L.I.C.S. with her, and Connie

and Felipe would have to search for her and L.I.C.S. On one of those occasions, Felipe found L.S.

by a Wal-Mart doing drugs with other people, while L.I.C.S. slept in the car. Felipe found L.I.C.S.

with L.S. by the same Wal-Mart on another occasion and reported L.S. “was out of her mind.”

The affidavit further provided L.S. was verbally and physically aggressive toward L.I.C.S. When

asked by the Department Investigator about her drug use, L.S. admitted she used drugs and would

test positive for methamphetamine if tested at that time.

The trial court signed an emergency removal order for L.I.C.S., named the Department

temporary managing conservator, and appointed an attorney and guardian ad litem. The court also

set June 4, 2020 for the full adversary hearing required by Chapter 262 of the Texas Family Code.

Under this order, the Department temporarily placed L.I.C.S. with a family friend. Thereafter, the

trial court reset the June 4, 2020 hearing to July 21, 2020. On July 21, 2020, a status hearing and

Chapter 262 adversary hearing occurred. The trial court ultimately issued a temporary order as to

L.I.C.S.’s father appointing the Department as temporary managing conservator, but it did not

enter a temporary order as to L.S. The Department then placed L.I.C.S. with a foster family.

The case proceeded to a permanency hearing followed by a two-day bench trial on April

29, 2021 and May 5, 2021. The trial court heard testimony from multiple witnesses, including

L.S.’s family members and friends, Department caseworkers and investigators, and L.S. After

3 The Department also sought termination of L.I.C.S.’s father’s parental rights, and his rights were ultimately terminated. He did not file a notice of appeal challenging the trial court’s order of termination, and as a result, he is not a party to this appeal. 4 S.S. is not a subject child to this appeal.

-2- 04-21-00287-CV

trial, the court found by clear and convincing evidence L.S. knowingly placed or allowed L.I.C.S.

to remain in conditions that endangered his physical or emotional well-being; engaged in conduct

or knowingly placed L.I.C.S. with persons who engaged in conduct that endangered his physical

or emotional well-being; failed to comply with court-ordered provisions of the family service plan;

and used a controlled substance in a manner that endangered L.I.C.S. See TEX. FAM. CODE ANN.

§ 161.001(b)(1)(D), (E), (O) & (P). The trial court also found by clear and convincing evidence

termination of L.S.’s parental rights was in L.I.C.S.’s best interest. See id. § 161.001(b)(2). L.S.

now appeals, arguing the trial court lacked jurisdiction to enter the order of termination and the

evidence is insufficient to support the trial court’s grounds for termination and the best-interest

finding.

JURISDICTION

We begin with L.S.’s argument challenging the trial court’s jurisdiction. L.S. argues the

court lacked jurisdiction to enter an order of termination because it failed to hold the Chapter 262

hearing and enter a temporary order applicable to her. According to L.S., because the court failed

to hold the hearing and enter a temporary order against her, it did not have any authority to require

L.S. to comply with her family service plan or terminate her parental rights.

Chapter 262 of the Texas Family Code sets forth the procedural requirements the

Department must take when removing a child from his home. In re C.M.D., No. 13-20-00402-

CV, 2021 WL 497302, at *3 (Tex. App.—Corpus Christi–Edinburg Feb. 11, 2021, no pet.) (mem.

op.). In urgent circumstances, Chapter 262 grants the Department emergency authority to remove

a child immediately from his home without prior notice to the child’s parents pursuant to an

emergency removal order. Id. (citing TEX. FAM. CODE ANN. §§ 262.101, 262.104). Following the

issuance of an emergency removal order, “a full adversary hearing shall be held not later than the

14th day after the date the child was taken into possession by the governmental entity, unless the

-3- 04-21-00287-CV

court grants an extension.” TEX. FAM. CODE ANN. § 262.201(a). This hearing, commonly referred

to as a Chapter 262 hearing, affords a parent the opportunity to present evidence and challenge the

Department’s evidence and right to retain the child. C.M.D., 2021 WL 497302, at *3. After the

hearing, a trial court may issue additional temporary orders appointing the Department as

temporary managing conservator and ordering a parent to comply with a family service plan. See

TEX. FAM. CODE § 262.201. However, if the full adversary hearing fails to show urgent

circumstances justified the immediate removal of a child from his home, Chapter 262 mandates

the child’s return to the parent. C.M.D., 2021 WL 497302, at *3 (citing TEX. FAM. CODE

§§ 262.201(g)(2)).

These provisions are procedural, not jurisdictional. In re J.M.C., 109 S.W.3d 591, 595

(Tex. App.—Fort Worth 2003, no pet.). If a party believes the trial court should have dismissed

the termination proceeding and returned the child to the parent, the party must timely raise this

complaint before a final order of termination occurs. See id. And, if a Chapter 262 hearing does

not occur, the proper remedy is for a parent to compel the trial court by mandamus to conduct an

adversarial hearing promptly and issue additional temporary orders. Id. Once a trial court renders

a final order of termination, any complaints about its temporary orders, or lack thereof, are moot.

C.M.D., 2021 WL 497302, at *4; In re A.K., 487 S.W.3d 679, 683 (Tex.

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