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

CourtCourt of Appeals of Texas
DecidedMarch 26, 2025
Docket04-24-00650-CV
StatusPublished

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

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-24-00650-CV

IN THE INTEREST OF L.J.C., a Child

From the 166th Judicial District Court, Bexar County, Texas Trial Court No. 2023PA00691 Honorable Laura Salinas, Judge Presiding

Opinion by: Rebeca C. Martinez, Chief Justice

Sitting: Rebeca C. Martinez, Chief Justice Lori I. Valenzuela, Justice Velia J. Meza, Justice

Delivered and Filed: March 26, 2025

AFFIRMED

This is an accelerated appeal from an order terminating the parental rights of appellant,

W.R.M. (“Mother”), to her child, L.J.C. 1 In her first issue, Mother challenges the sufficiency of

the evidence to support the jury’s finding that termination of her parental rights is in L.J.C.’s best

interest. See TEX. FAM. CODE ANN. § 161.001(b)(2). In her second issue, Mother contends that

her trial counsel rendered ineffective assistance by failing to preserve her sufficiency challenge for

appellate review. We affirm.

1 To protect the identities of L.J.C. and her half-siblings, we refer to all minors and adults as necessary by their initials or aliases. See TEX. FAM. CODE ANN. § 109.002(d); TEX. R. APP. P. 9.8(b)(2). 04-24-00650-CV

BACKGROUND

Mother’s parental rights to her first three children were terminated in two prior

proceedings. L.J.C., Mother’s fourth child, was born on April 26, 2023. On May 9, 2023, the

Texas Department of Family and Protective Services (the “Department”) filed a petition to

terminate Mother’s parental rights to L.J.C. That same day, the trial court ordered the Department

to be named as the child’s temporary sole managing conservator. Two days later, L.J.C. was

discharged from a neonatal intensive care unit at the hospital and placed into a foster home with

her half-brother, D.S.R., who was two years old at the time. There, she resided through the time

of trial.

From L.J.C.’s removal to nearly the eve of trial, sixteen months later, the Department’s

primary goal was reunification of L.J.C. with her Mother. In furtherance of that goal, in August

2024, Mother filed a motion for the monitored return of L.J.C. to her care. However, in September

2024, the Department’s primary goal changed to termination of Mother’s parental rights. On

September 16 and 17, 2024, the trial court held an evidentiary hearing on Mother’s motion for

monitored return and, at the conclusion of the hearing, denied the motion. 2 The next day, a three-

day jury trial commenced on the termination of Mother’s parental rights. The trial court admitted

over two dozen exhibits, and the jury heard from six witness: Leah Jarma, who was the

Department’s caseworker during the prior cases that resulted in the termination of Mother’s

parental rights to L.J.C.’s half-siblings; Ida Pierce, the Department’s program director; Laura

Irons, the Department’s caseworker for L.J.C.’s case; the court appointed special advocate

(“CASA”); L.J.C.’s foster father (“Foster Father”); and Mother.

2 On September 17, 2024, the trial court also rendered an interlocutory order of termination as to L.J.C.’s unknown father, which was later incorporated into the final order of termination.

-2- 04-24-00650-CV

Mother did not move for an instructed verdict after the conclusion of the Department’s case

in chief or object to the submission of any issue to the jury. The jury found, by clear and

convincing evidence, that Mother knowingly placed or knowingly allowed L.J.C. to remain in

conditions or surroundings which endangered the child’s physical and emotional well-being, see

id. § 161.001(b)(1)(D); engaged in conduct or knowingly placed L.J.C. with persons who engaged

in conduct which endangered the child’s physical and emotional well-being, see id.

§ 161.001(b)(1)(E); had her parent-child relationship terminated with respect to another child

based on an endangerment finding, see id. § 161.001(b)(1)(M); failed to comply with the

provisions of a court order that specifically established the actions necessary for the return of

L.J.C., see id. § 161.001(b)(1)(O); and had been the cause of L.J.C. being born addicted to a

controlled substance, see id. § 161.001(b)(1)(R). Additionally, the jury found that termination of

Mother’s parental rights was in L.J.C.’s best interest. See id. § 161.001(b)(2).

The trial court rendered an order of termination conforming with the verdict on September

20, 2024, and signed a written order of termination on October 1, 2024. Mother did not file a

motion for judgment notwithstanding the verdict, a motion to disregard the jury’s answer to a vital

fact issue, or a motion for new trial. She, however, timely appealed. Mother contends on appeal

that the evidence was legally and factually insufficient to support the jury’s finding that

termination of Mother’s parental rights was in L.J.C.’s best interest. She also argues that her trial

counsel unjustifiably failed to preserve her sufficiency challenge for appellate review.

PRESERVATION

For preservation of a legal sufficiency challenge following a jury trial, a party must have

(1) moved for an instructed verdict, (2) moved for judgment notwithstanding the verdict, (3)

objected to submission of the issue to the jury, (4) moved to disregard a jury’s answer to a vital

-3- 04-24-00650-CV

fact issue, or (5) moved for a new trial. In re D.T., 625 S.W.3d 62, 75 n.8 (Tex. 2021); In re

C.C.O., No. 04-24-00268-CV, 2024 WL 4897188, at *3 (Tex. App.—San Antonio Nov. 27, 2024,

no pet.). For preservation of a factual sufficiency challenge following a jury trial, a party must

have moved for new trial. TEX. R. CIV. P. 324(b)(2); In re D.T., 625 S.W.3d at 75 n.8; In re C.C.O.,

No. 04-24-00268-CV, 2024 WL 4897188, at *3. Mother took none of these actions.

Nevertheless, because termination proceedings implicate fundamental liberties, we

sometimes may review unpreserved error. See In re B.L.D., 113 S.W.3d 340, 351–55 (Tex. 2023);

In re M.S., 115 S.W.3d 534, 546, 550 (Tex. 2003); In re C.C.O., No. 04-24-00268-CV, 2024 WL

4897188, at *3. As we recently summarized:

We must apply our error-preservation rules, but we may deviate from them if a parent demonstrates that his or her counsel’s failure to preserve a factual sufficiency complaint was unjustified, see In re M.S., 115 S.W.3d at 549–50, and we potentially may deviate from our error-preservation rules if a parent demonstrates that his or her counsel’s failure to preserve a legal sufficiency complaint was unjustified, see In re J.P.B., 180 S.W.3d [570, 574 (Tex. 2005)]. Both of these exceptions incorporate the Strickland standard. See In re M.S., 115 S.W.3d at 549; In re J.P.B., 180 S.W.3d at 574.

In re C.C.O., No. 04-24-00268-CV, 2024 WL 4897188, at *5. Under the two-prong Strickland

test, to establish ineffective assistance of counsel, a party must show (1) that his or her counsel’s

performance was deficient and (2) that counsel’s deficient performance prejudiced the party’s

defense. See Strickland v. Washington, 466 U.S. 668, 687 (1984); In re J.O.A., 283 S.W.3d 336,

341–42 (Tex. 2009). Thus, for a parent to show that his or her counsel unjustifiably failed to

preserve error, such that we could dispose with our usual error-preservation requirements in a

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