In the Interest of T.K. Jr. v. the State of Texas

CourtCourt of Appeals of Texas
DecidedAugust 3, 2023
Docket09-23-00103-CV
StatusPublished

This text of In the Interest of T.K. Jr. v. the State of Texas (In the Interest of T.K. Jr. 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 T.K. Jr. v. the State of Texas, (Tex. Ct. App. 2023).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-23-00103-CV __________________

IN THE INTEREST OF T.K. JR.

__________________________________________________________________

On Appeal from the 279th District Court Jefferson County, Texas Trial Cause No. F-238,183-A __________________________________________________________________

MEMORANDUM OPINION

Father and Mother appeal the trial court’s order terminating their parental

rights to their child, T.K. Jr.1 In a single issue, Father and Mother argue the trial

court erred by denying their Pleas to the Jurisdiction. They assert the Texas court

lacked subject matter jurisdiction under the Uniform Child Custody Jurisdiction and

Enforcement Act (“UCCJEA”) because Texas is not T.K. Jr.’s “home state.” See

1 We identify children and their family members in parental-rights termination cases by using either initials or their relationship to the child. See Tex. R. App. P. 9.8(a), (b).

1 Tex. Fam. Code Ann. § 152.201. We conclude the Texas court had jurisdiction under

the UCCJEA and affirm the trial court’s final termination order.

PERTINENT BACKGROUND

In March 2022, the Texas Department of Family and Protective Services (“the

Department”) filed an Original Petition for Protection of a Child, for

Conservatorship and for Termination in Suit Affecting the Parent-Child Relationship

between T.K. Jr. and his parents. The Department attached an affidavit for

Emergency Removal in which Schrietta Henson averred that the Department

received a report alleging neglectful supervision of two-week old T.K. Jr. by his

parents, who lived in Beaumont. Henson stated that a jury had recently terminated

the parents’ parental rights to T.K. Jr.’s sibling, K.K.,2 and during the prior case,

Mother tested positive for methamphetamines while pregnant with T.K. Jr. Henson

explained that Father also tested positive for methamphetamines and the parents had

denied Mother was pregnant with T.K. Jr. in the prior termination of Father’s and

Mother’s parental rights as to K.K. After T.K. Jr. was born, the parents hid T.K. Jr.

from the Department. Henson further explained that the Department was concerned

about T.K. Jr.’s safety and believed the Department should be named T.K. Jr.’s

Temporary Managing Conservator.

2 The record reflects that K.K. was born in October 2020. The trial on the termination of Mother’s and Father’s rights to K.K. occurred in March 2022. 2 The trial court issued an Order of Protection of a Child in an Emergency and

Notice of Hearing, finding, among other things, that it had jurisdiction under section

262.002 of the Texas Family Code and naming the Department as temporary sole

managing conservator of T.K. Jr. The Department filed a Petition for Writ of Habeas

Corpus, stating the parents were illegally restraining T.K. Jr. in Jefferson, County,

Texas, and attempting to hide the child from the Department. The Department filed

a Motion for Writ of Attachment, asking the trial court to grant a writ to take physical

custody of T.K. Jr., who the Department believed was in danger. The trial court

issued a Writ of Attachment, ordering the delivery of T.K. Jr. into the possession of

the Department.

In April 2022, the 27th Judicial District Court of Louisiana (“the Louisiana

Court”) issued an Instanter Order for Removal and Provisional Custody to the

Department of Children and Family Services, in which the Louisiana Court found

there were reasonable grounds to believe T.K. Jr. was in need of care and temporary

emergency removal was necessary to secure the child’s protection and that

continuance of the child in the home of the parents would be contrary to the child’s

health, safety, and welfare. In its Order, the Louisiana Court found that (1) based on

the information provided by the Texas Court, it was necessary for the State of

Louisiana to obtain an emergency custody order being that T.K. Jr. was located in

Louisiana in Father’s custody; and (2) in accordance with the documentation the

3 Department provided, including a writ of attachment, T.K. Jr. was located in

Louisiana after being removed from Texas. After T.K. Jr. was placed in Louisiana’s

provisional custody, the Louisiana Court vacated its Instanter Order for Removal

and Provisional Custody and returned T.K. Jr. to the Department by order of the

Texas Court.

Upon T.K. Jr.’s return to Texas, the trial court conducted a hearing in April

2022, during which Schrietta Henson, a conservatorship supervisor with the

Department, testified that she was the caseworker in the parents’ prior case which

resulted in termination of the parents’ rights to K.K., and she explained that the case

was tried in March 2022, the same month Mother gave birth to T.K. Jr. Henson

testified that Mother tested positive for methamphetamines while pregnant, and at

one month of age, T.K. Jr. tested positive for methamphetamines and marijuana.

Henson explained that the parents did not provide any medical records regarding

T.K. Jr.’s birth and while she did not see the child in Texas with the parents, the

Department received numerous complaints that the child was in Texas. Henson also

explained that the parents’ last known address was in Beaumont, but she was unsure

of where they currently lived. Henson testified T.K. Jr. was removed from Louisiana.

Henson testified that T.K. Jr. was now living in a foster home. As to the removal of

T.K. Jr., the Department had concerns about T.K. Jr.’s safety and well-being if T.K.

Jr. was returned to Mother and Father and believed it was in T.K. Jr.’s best interest

4 that the Department be appointed as his Temporary Managing Conservator. The trial

court found “there was a danger to the physical health or safety of [T.K. Jr.,”] there

was an “urgent need for protection require[ing] the immediate removal of [T.K. Jr.,”]

“reasonable efforts [had] been made to enable [T.K. Jr.’s return home, but there was]

a substantial risk of a continuing danger if [he] [was] returned home[.]” The court

also found that appointing T.K.’s parents as his Temporary Managing Conservators

would not be in his best interest while appointing the Department as his Temporary

Managing Conservator would be in his best interest. Finally, the trial court found

that based on the evidence presented in the hearing and on the record, “all necessary

prerequisites of the law have been satisfied and that this [c]ourt has jurisdiction of

this case and of all parties.”

In a status hearing conducted around a month later, Henson testified that it

was her understanding that Mother and Father lived in Beaumont, and she confirmed

that Mother and Father had recently worked in Beaumont. Mother’s attorney asked

Henson about Mother’s and Father’s testimony during the prior trial that ended right

before the Department filed the current petition. Mother’s attorney asked if Henson

had any information that the parents’ testimony that they had been working in

Louisiana was false, and Henson explained that the parents never provided

documentation regarding their employment in Louisiana.

5 In June 2022, Father and Mother filed Pleas to the Jurisdiction, arguing the

Texas Court lacked jurisdiction over T.K. Jr.

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