In the Interest of T.K., L.T.K., L.J., and L.A.K., Children. v. the State of Texas

CourtCourt of Appeals of Texas
DecidedOctober 28, 2024
Docket05-24-00822-CV
StatusPublished

This text of In the Interest of T.K., L.T.K., L.J., and L.A.K., Children. v. the State of Texas (In the Interest of T.K., L.T.K., L.J., and L.A.K., Children. 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., L.T.K., L.J., and L.A.K., Children. v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

AFFIRMED and Opinion Filed October 28, 2024

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-24-00822-CV

IN THE INTEREST OF T.K., L.T.K., L.J., AND L.A.K., CHILDREN

On Appeal from the 304th Judicial District Court Dallas County, Texas Trial Court Cause No. JC-21-01161-W

MEMORANDUM OPINION

Before Justices Reichek, Goldstein, and Garcia Opinion by Justice Garcia

This appeal arises from a proceeding to terminate parental rights as to four

children. Appellant Father was adjudicated to be the father of only one of the four

children, L.J. After a bench trial, the judge signed a decree terminating all parents’

rights as to all four children. Father appeals. We affirm.

I. BACKGROUND

On December 10, 2021, the Texas Department of Family and Protective

Services filed an original petition seeking, among other things, to terminate parental

rights as to four children: T.K. (male; five years old), L.T.K. (female; three years

old), L.J. (female; almost two years old), and L.A.K. (female; a few months old). The Department alleged that Mother was the mother of all four children and that

Father was the father of L.T.K. and L.J. The Department further alleged that it had

already taken possession of the children based on evidence that T.K. and L.T.K. had

been physically abused. On the same day, a judge signed an ex parte order for

emergency care and temporary custody of the children.

Genetic testing established that Father was L.J.’s father but was not L.T.K.’s

father. According to the final decree, the fathers of L.T.K. and L.A.K. were

unknown.

On December 8, 2022, the trial judge signed an order directing the immediate

monitored return of L.J. and L.A.K. to Mother. T.K. and L.T.K. were also to be

returned to Mother on a monitored basis by January 6, 2023. The same order

extended the case’s dismissal date to June 9, 2023.

The deadline to return T.K. and L.T.K. to Mother was later extended to March

17, 2023.

A report by Dallas Court Appointed Special Advocates indicates that on

March 5, 2023, Mother contacted the Department and said that she wanted L.J. and

L.A.K. removed from her care. On March 8, 2023, the trial judge signed an ex parte

order removing the children.

On April 7, 2023, the trial judge signed an order extending the case’s dismissal

date to September 1, 2023. The same order set the case for trial “on August , 2023

[sic].”

–2– On August 15, 2023, the trial judge began the bench trial of this case. She

swore in the witnesses, took appearances, and heard testimony from caseworker

Meredith Reeder to the effect that some DNA testing was pending and that the

Department was asking for a recess to allow the completion of that testing. The

Department’s attorney also advised the judge that a mediation was pending and that

the Department believed it was premature to try to conclude the trial at that time.

The judge recessed the trial until October 24, 2023.

The trial resumed and concluded on June 11, 2024. That same day, a partial

mediated settlement agreement (MSA) was filed in the case. In that MSA, Mother

agreed to the termination of her rights as to all four children, and T.K.’s father agreed

to the termination of his rights as to T.K. Thus, the trial focused on Father’s parental

relationship with L.J. After the close of evidence, the judge orally ruled that Father’s

parent–child relationship with L.J. would be terminated.

On June 21, 2024, the trial judge signed the decree terminating all four

children’s parent–child relationships with their parents. The decree included findings

that Father committed the conduct defined in Family Code § 161.001(b)(1)(D) and

(E), as well as a finding that terminating Father’s parent–child relationship with L.J.

was in L.J.’s best interest. Father timely appealed.

II. JURISDICTION

Shortly after Father perfected this appeal, we sent the parties a letter

questioning whether the trial court lost jurisdiction in this case before it rendered

–3– judgment. See TEX. FAM. CODE ANN. §§ 263.401, 263.403. We noted that the

computer-generated case summary reflected that there was a bench trial on August

15, 2023, but nothing else in the record supported that fact. Accordingly, we solicited

jurisdictional letter briefs from the parties.

A few weeks later, we received and filed a supplemental reporter’s record of

the proceedings held on August 15, 2023. As discussed above, that record reflects

that on that date the trial judge swore in the witnesses, took appearances, and heard

testimony from one witness, caseworker Meredith Reeder. This was sufficient to

constitute commencement of the trial on the merits for Family Code purposes. See

In re H.B.C., No. 05-19-00907-CV, 2020 WL 400162, at *12 (Tex. App.—Dallas

Jan. 23, 2020, no pet.) (mem. op.).

Because the trial on the merits commenced before the extended automatic

dismissal date of September 1, 2023, we conclude that the trial court did not lose

jurisdiction over this case under § 263.401 and § 263.403.

III. ISSUES PRESENTED

Father presents two issues on appeal. In his first issue, he challenges the legal

and factual sufficiency of the evidence to support the trial judge’s finding that

termination was in L.J.’s best interest. In his second issue, he challenges the trial

judge’s appointment of the Department as L.J.’s permanent managing conservator.

–4– IV. STANDARD OF REVIEW

Because terminating parental rights implicates fundamental interests, the clear

and convincing standard of proof applies at trial in termination cases. In re A.B.,

437 S.W.3d 498, 502 (Tex. 2014). “Clear and convincing evidence” is the measure

or degree of proof that will produce in the factfinder’s mind a firm belief or

conviction as to the truth of the allegations to be established. FAM. § 101.007.

Our standards of review reflect the elevated burden of proof at trial. In re A.C.,

559 S.W.3d 176, 180 (Tex. App.—Dallas 2017), aff’d, 560 S.W.3d 624 (Tex. 2018).

Under both legal- and factual-sufficiency standards, we consider all the evidence,

defer to the factfinder’s determinations as to witness credibility, and determine

whether the factfinder could reasonably form a firm belief or conviction that the

grounds for termination were proven. Id.; see also In re A.B., 437 S.W.3d at 503

(describing the factfinder as “the sole arbiter when assessing the credibility and

demeanor of witnesses”). The distinction between the two standards lies in the extent

to which we may consider disputed evidence contrary to a finding. In re A.C., 560

S.W.3d 624, 630 (Tex. 2018).

In a legal-sufficiency review, we credit evidence that supports the finding if a

reasonable factfinder could have done so, and we disregard contrary evidence unless

a reasonable factfinder could not have done so. See In re K.M.L., 443 S.W.3d 101,

112 (Tex. 2014). However, we do not disregard undisputed facts that do not support

the finding. Id. at 113.

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Holley v. Adams
544 S.W.2d 367 (Texas Supreme Court, 1976)
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In the Interest of T.K., L.T.K., L.J., and L.A.K., Children. v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-tk-ltk-lj-and-lak-children-v-the-state-texapp-2024.