In the Interest of R.R.G. IV, a Child v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJuly 6, 2023
Docket13-23-00032-CV
StatusPublished

This text of In the Interest of R.R.G. IV, a Child v. the State of Texas (In the Interest of R.R.G. IV, a Child v. the State of Texas) 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.

Bluebook
In the Interest of R.R.G. IV, a Child v. the State of Texas, (Tex. Ct. App. 2023).

Opinion

NUMBER 13-23-00032-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

IN THE INTEREST OF R.R.G. IV, A CHILD

On appeal from the County Court at Law No. 5 of Nueces County, Texas.

MEMORANDUM OPINION Before Chief Justice Contreras and Justices Benavides and Longoria Memorandum Opinion by Justice Benavides

Appellants A.A.N.P. (Alexis) and R.G. III (Ryan)1 appeal from the trial court’s final

order terminating their parental rights to R.R.G. IV (Roger). Alexis and Ryan both argue

that the trial court’s jurisdiction was extinguished when it failed to render an order

extending the automatic dismissal date prior to the deadline lapsing. See TEX. FAM. CODE

ANN. § 263.401(b). Alexis additionally argues that the trial court erred by: (1) terminating

1 We identify the parties and child in this case by aliases. See TEX. R. APP. P. 9.8(b)(2). her parental rights when the evidence was legally and factually insufficient to show that it

was in Roger’s best interest; and (2) denying her motion for new trial based on newly

discovered evidence.2 We affirm.

I. PROCEDURAL BACKGROUND

On May 10, 2021, the Texas Department of Family and Protective Services (the

Department) filed an original petition for the protection of Roger and to terminate the

parental rights of Alexis and Ryan. According to the affidavit in support of removal

attached to the petition, the Department received a report of potential child neglect on

May 4, 2021. As part of its preliminary investigation, the Department learned that Roger

was born testing positive for methylenedioxymethamphetamine (MDMA), amphetamine,

and benzodiazepine. Alexis submitted to a urinalysis test, which yielded positive results

for methamphetamine.

That same day, the trial court signed an order removing the child from the parents’

custody and appointing the Department as temporary managing conservator. Throughout

the course of the proceedings, Alexis was permitted two-hour supervised visits with Roger

twice weekly. On May 16, 2022, the trial court signed an order requiring Alexis to complete

inpatient drug treatment.

Trial commenced on November 7, 2022. At the conclusion of trial, the court took

the matter under advisement. On December 28, 2022, the trial court signed an order

terminating Alexis’s and Ryan’s parental rights and finding that the termination was in

Roger’s best interest. Alexis filed a motion for new trial based on newly discovered

2 We have renumbered Alexis’s issues. 2 evidence, but the trial court denied the motion. This accelerated appeal followed. See

TEX. R. APP. P. 28.4.

II. JURISDICTION

Alexis and Ryan contend that the trial court lost jurisdiction over the termination

proceedings by failing to extend the automatic dismissal deadline.

A. Standard of Review & Applicable Law

“Before a court may enter judgment against a party, the court must have obtained

jurisdiction over that party pursuant to applicable rules or statutes.” Whatley v. Walker,

302 S.W.3d 314, 321 (Tex. App.—Houston [14th Dist.] 2009, pet. denied). A judgment is

void when the court rendering judgment had no jurisdiction over the parties or property,

no jurisdiction over the subject matter, no jurisdiction to enter the particular judgment, or

no capacity to act. In re D.S., 602 S.W.3d 504, 512 (Tex. 2020). We review whether a

trial court has jurisdiction de novo. Joyner v. Joyner, 352 S.W.3d 746, 749 (Tex. App.—

San Antonio 2011, no pet.).

“Section 263.401 of the Texas Family Code establishes a deadline for rendition of

a final order in suits affecting the parent-child relationship (SAPCRs) brought by the

[Department].” In re Tex. Dep’t of Fam. & Protective Servs., 210 S.W.3d 609, 611 (Tex.

2006) (orig. proceeding) (op. on reh’g). This provision requires trial courts to commence

a trial on the merits by “the first Monday after the first anniversary of the date the court

rendered a temporary order appointing the department as temporary managing

conservator.” TEX. FAM. CODE ANN. § 263.401(a). If the trial court finds certain

extraordinary circumstances exist, the statute allows the trial court to extend the deadline

3 by a maximum of 180 days. Id. § 263.401(b); In re Tex. Dep’t of Fam. & Protective Servs.,

210 S.W.3d at 612. “But if the trial court neither commences trial by the dismissal date

nor extends it in accordance with [§] 263.401(b), the statute dictates a dire consequence:

the trial court’s jurisdiction over the suit ‘is terminated and the suit is automatically

dismissed.’” In re G.X.H., 627 S.W.3d 288, 292 (Tex. 2021) (quoting TEX. FAM. CODE ANN.

§ 263.401(a)).

B. Analysis

On May 10, 2021, the trial court rendered a temporary order appointing the

Department as temporary managing conservator. This made the automatic dismissal date

May 16, 2022. See TEX. FAM. CODE ANN. § 263.401(a). At a docket call on May 5, 2022,

the Department and counsel for Alexis informed the trial court that the automatic dismissal

deadline was looming and that the trial court had not extended the deadline yet. Counsel

for Ryan announced that he was not ready for trial. Counsel for Alexis discussed her

client’s attempts to begin inpatient drug treatment and stated the case “need[ed] an

extension.” The trial court pronounced, “Okay. I’ll order the [263.]401 [extension], but let’s

set it for trial. If she gets into treatment—I mean, that’s the goal here. . . . If she’s in

treatment in 45 days, my inclination will be to let her finish her treatment.” However, the

trial court failed to explicitly make the findings mandated by § 263.401(b). See id.

§ 263.401(b). No party objected to the trial court’s oral rendition of the extension or its

omission of the required findings. See TEX. R. APP. P. 33.1(a). On May 27, 2022, the trial

court signed a written order setting the new dismissal date as November 13, 2022, and

explicitly finding “that extraordinary circumstances necessitate the subject child[

4 ]remaining in the temporary managing conservatorship of the Department and that

continuing the appointment of the Department as temporary managing conservator is in

the best interest of the subject child.” See TEX. FAM. CODE ANN. § 263.401(b).

We conclude the trial court’s pronouncement that it would “order the [263.]401

[extension]” was sufficient to extend the mandatory dismissal deadline. See id. § 101.026;

In re G.X.H., 627 S.W.3d at 299 (explaining that Texas Family Code § 101.026 “permits

trial courts to render orders orally in the presence of the court reporter”); see also In re

J.P., No. 13-18-00648-CV, 2020 WL 103858, at *4 (Tex. App.—Corpus Christi–Edinburg

Jan. 9, 2020, pet. denied) (mem. op.) (holding that the trial court rendered judgment when

it stated, “The Court will approve the agreement of the parties and I will order the release

of [Mother]”). However, both Alexis and Ryan urge that because the trial court failed to

explicitly make the findings required by § 263.401(b) prior to the expiration of the original

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