J. G. v. Texas Department of Family and Protective Services

CourtCourt of Appeals of Texas
DecidedMay 25, 2023
Docket03-22-00790-CV
StatusPublished

This text of J. G. v. Texas Department of Family and Protective Services (J. G. v. Texas Department of Family and Protective Services) 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
J. G. v. Texas Department of Family and Protective Services, (Tex. Ct. App. 2023).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-22-00790-CV

J. G., Appellant

v.

Texas Department of Family and Protective Services, Appellee

FROM THE 459TH DISTRICT COURT OF TRAVIS COUNTY NO. D-1-FM-21-000779, THE HONORABLE AURORA MARTINEZ-JONES, JUDGE PRESIDING

MEMORANDUM OPINION

J.G. (Mother) appeals from the trial court’s decree terminating her parental rights

to her son, Jordan.1 See Tex. Fam. Code § 161.001(b). Mother challenges the legal and factual

sufficiency of the evidence supporting the trial court’s findings and argues that she established an

affirmative defense to termination due to an alleged disability and the Department’s failure to

provide her necessary accommodations therefor. See id. § 161.001(b)(1)(N), (O), (2), (d). For

the following reasons, we affirm the trial court’s termination decree.

BACKGROUND AND SUMMARY OF THE EVIDENCE

In February 2021, the Department filed an original petition in a suit affecting the

parent-child relationship (SAPCR) seeking termination of Mother’s parental rights and/or

1 For the child’s privacy, we will refer to him by an alias and to his family members by their relationships to him or by aliases. See Tex. R. App. P. 9.8. managing conservatorship of Jordan.2 In the petition, the Department alleged that temporary

orders were necessary for the safety and welfare of Jordan, including the appointment of the

Department as the child’s temporary managing conservator. Attached to the petition was an

Affidavit in Support of Extraordinary Relief in which Department investigator Steven Guillory

averred that the Department had taken emergency custody of Jordan due to immediate danger to

him caused by Mother’s neglectful supervision.

In the affidavit, Guillory represented that then one-year-old Jordan has intensive

medical needs, including needing to be fed through a G-tube,3 and was living in a shelter with

Mother at the time, and that two months prior to Jordan’s removal the Department received a

referral that Mother had been under the influence of marijuana while caring for Jordan.

Immediately before Jordan’s removal, the Department received a second referral alleging that

Mother admitted she had been too intoxicated—from drinking alcohol and using marijuana—to

replace Jordan’s G-tube, which had fallen out, and had called 911 for assistance. Jordan was

transported to the hospital, and EMS would not allow Mother to accompany Jordan in the

ambulance due to her level of intoxication. During the investigation of the second referral,

Mother admitted that she had been too intoxicated to replace Jordan’s feeding tube and that

2 The Department also sought termination of the parental rights of Jordan’s unknown father, and the final decree terminated the unknown father’s rights after finding that he had not registered with the paternity registry under Family Code Chapter 160 and that the Department had exercised due diligence in determining his identity and location. See Tex. Fam. Code § 161.002(b)(2)(A). 3 A G-tube (also known as a gastric or gastrostomy feeding tube) is a tube inserted through a small incision in the abdomen into the stomach that is used for long-term enteral nutrition. See Feeding Tube, Wikipedia, https://en.wikipedia.org/wiki/Feeding_tube#Gastric_ feeding_ tube (last visited May 19, 2023).

2 everyone present at the time of the incident was also high and intoxicated, resulting in no sober

caregiver being present.

The Department placed Jordan in a medical-needs foster home for the duration of

the case. The parties entered into a mediated settlement agreement (MSA) in January 2022, by

which they agreed to a statutory extension of the case’s deadline and that Mother (1) “shall visit

with the child as scheduled by the Department” and “confirm each visit 24 hours in advance”;

(2) “shall participate in all drug testing requirements within 24 hours of any such request

from the Department”; and (3) “shall attend Marijuana Anonymous and shall provide proof

of attendance to the Department,” among other stipulations. The trial court rendered an order

extending the dismissal date per the parties’ agreement and incorporating the provisions of the

MSA pertaining to the required actions of Mother.

On May 9, 2022, Mother filed a motion for continuance of that date’s scheduled

merits hearing, arguing that in March and per court order, she had been evaluated by a

psychologist and been diagnosed with “borderline intellectual functioning, with an IQ of 66, well

below the cutoff of 70-75 for a diagnosis of Intellectual Disability.” In her motion, Mother

further argued that—while she had previously made “multiple attempts” to execute an affidavit

of relinquishment of parental rights, which were not successful “due to logistical problems”—

she recently had “indicated a desire to maintain parental rights.” She sought the continuance to

afford the parties a chance to again mediate the case. The trial court granted the continuance,

authorized mediation, and set trial dates of July 18, 25, and August 1. On May 10, Mother filed

her “First Amended Answer and Counter-Petition with Americans with Disabilities Act Claim,”

in which she raised as an affirmative defense to the (O) ground for termination, see Tex. Fam.

Code § 161.001(b)(1)(O), that she (1) had been unable to comply with specific provisions of the

3 court order and (2) had made a good-faith effort to comply with the order and that her failure

to comply was not attributable to her fault, see id. § 161.001(d). She additionally asserted an

affirmative defense under the Americans with Disabilities Act (ADA), see 42 U.S.C. § 12102,

identifying herself as having “an intellectual disability and mental illness.” She asserted that the

Department is required to “make reasonable accommodations to enable [her] meaningful access

to services,” specifically requiring the following accommodations: “more time to process

information; less stressful settings for visitation and meetings; and repeated and simplified

explanations for requirements and requests made of her.”

Trial to the court commenced August 9, 2022, but—after brief initial testimony by

the caseworker—was recessed and continued by the parties’ agreement. Trial recommenced and

concluded October 20, 2022.

Evidence admitted at trial

Relevant to the issues on appeal, the trial court admitted into evidence the

removal affidavit, several of the court’s orders prescribing the actions Mother must take to obtain

the return of Jordan, and the parties’ MSA. Three witnesses testified: Department caseworker

Shawn Schroeder, Mother, and the foster mother.

Schroeder testified that he became the caseworker for this case in early April

2022 and reviewed the case file, learning about Jordan’s current medical condition and needs

(he had a G-tube and was recovering from a staph infection) and the reasons for Mother’s

involvement with the Department. He explained that, from the December 2020 intake—when

Mother and Jordan were staying at a women’s shelter and she had been found to be under the

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J. G. v. Texas Department of Family and Protective Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/j-g-v-texas-department-of-family-and-protective-services-texapp-2023.