in the Interest of N.L.G., a Child

Procedural entryThis page is a short order in in the Interest of N.L.G., a Child. Read the opinion of the Court — 2007 Tex. App. LEXIS 8104
Court of Appeals of Texas·Decided October 11, 2007·No. 02-06-00347-CV·Published

Opinion

COURT OF APPEALS

SECOND DISTRICT OF TEXAS

FORT WORTH

NO. 2-06-347-CV

IN THE INTEREST OF N.L.G., A CHILD                                                   

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FROM THE 362ND DISTRICT COURT OF DENTON COUNTY

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OPINION

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I.  Introduction

The Texas Department of Family and Protective Services (ATDFPS@) brought suit to terminate the parental rights of Sarah W. to her five-day-old daughter, N.L.G.  Following a jury trial, the trial court signed a judgment terminating Sarah=s parental rights.[1]  In her sole point, Sarah argues that the trial court abused its discretion by allowing N.L.G.=s foster parents to intervene in the suit.  We will affirm.


II.  Factual and Procedural Background

In April 2005, Sarah gave birth to N.L.G.  After both mother and child tested positive for methamphetamine, the hospital contacted TDFPS.   A TDFPS caseworker investigated Sarah=s drug use, evaluated her interaction with N.L.G., and ultimately took the child into State custody when the child was two days old.  TDFPS placed the child with foster parents Randall and Brenda N. five days later and instituted termination proceedings against Sarah. 

The trial court initially set the termination trial for March 2006, but upon a request from Sarah for a continuance, reset it for August 14, 2006.  On July 14, the foster parents filed a petition to intervene in the termination trial.  Sarah moved to strike the petition to intervene on the ground that it was filed less than thirty days before trial, and she was therefore unable to conduct proper discovery on the intervenors= claims.  After a hearing on the motion, the trial court allowed the foster parents to intervene, reset the trial for September 25, 2006, and ordered the intervenors to submit to Sarah=s discovery requests. 

At trial, the jury found that termination of Sarah=s parental rights was in the best interest of N.L.G., and the trial court entered a termination order pursuant to this determination.  Sarah now appeals.


III.  Standing of the Foster Parents

In her sole point, Sarah complains that the trial court erred by failing to strike the foster parents= plea in intervention because they lacked standing.[2]  The standard of review for determining whether the trial court improperly denied a motion to strike intervention is abuse of discretion.  Guar. Fed. Sav. Bank v. Horseshoe Operating Co., 793 S.W.2d 652, 657 (Tex. 1990); Law Offices of Windle Turley v. Ghiasinejad, 109 S.W.3d 68, 70 (Tex. App.CFort Worth 2003, no pet.).  To determine whether a trial court abused its discretion, we must decide whether the trial court acted without reference to any guiding rules or principles; in other words, we must decide whether the act was arbitrary or unreasonable.  Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238, 241-42 (Tex. 1985), cert. denied, 476 U.S. 1159 (1986).


In 1995, the Texas Legislature passed new laws specifically implicating the ability of foster parents to be heard in trial court regarding their foster children.  See Act of Apr. 6, 1995, 74th Leg., R.S., ch. 20, ' 1, 1995 Tex. Gen. Laws 113, 125 (amended 1997) (current version at Tex. Fam. Code Ann.  ' 102.003-.004 (Vernon Supp. 2006)).  Foster parents now have two avenues to the courthouse.  First, foster parents can bring an original suit affecting the parent child relationship (SAPCR) if the child has lived with the foster parents Afor at least [twelve] months ending not more than [ninety] days preceding the date of the filing of the petition.@  Tex. Fam. Code Ann. ' 102.003(a)(12) (Vernon Supp. 2006). 

Second, foster parents who have not had possession of the child for at least twelve months ninety days before they file suit may nevertheless intervene in a SAPCR brought by someone with standing if the foster parents can demonstrate that they have had substantial past contact with the child.  Id. at ' 102.004(b).


The substantial past contact test established by section 102.004(b) for foster parent intervenors was a dramatic change from the traditional intervenor standing requirement.  For several years, the Texas Supreme Court case of

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