James v. Texas Department of Human Services

836 S.W.2d 236, 1992 WL 151954
CourtCourt of Appeals of Texas
DecidedJuly 7, 1992
Docket6-90-028-CV
StatusPublished
Cited by17 cases

This text of 836 S.W.2d 236 (James v. Texas Department of Human 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
James v. Texas Department of Human Services, 836 S.W.2d 236, 1992 WL 151954 (Tex. Ct. App. 1992).

Opinion

OPINION

BLEIL, Justice.

Carrie James appeals from a judgment terminating her parental rights to two of her children, a boy and a girl, aged nine and eleven, respectively, at the time of trial. The trial also resulted in the termination of the parental rights of Sherman Goodson, the children’s father. 1 The significant issues material to our decision concern preliminary trial court rulings, eviden-tiary rulings, the sufficiency of the evidence, and the jury instructions. We conclude that the trial court erred in several evidentiary rulings which normally would dictate a reversal of the judgment. However, because other properly admitted evidence shows clearly and convincingly that there are grounds for termination, and that termination is in the best interests of the children, we find no reversible error and affirm.

PRELIMINARY RULINGS

Initially, we consider the complaints concerning the trial court’s preliminary rulings. The complaints concern the action of the trial court in failing to grant all of James’ special exceptions to the pleadings, in allowing the State to file amended pleadings three days before trial, and in failing to sever her trial from that of Sherman Goodson.

James shows no error with respect to these preliminary rulings. Concerning the special exceptions, no appellate complaint is preserved because the trial court did not rule on the special exceptions (Tex.R.App.P. 52(a)); further, no special exceptions were levied against the pleadings on which the case was tried, thus no error is shown. Wray v. Lenderman, 640 S.W.2d 68, 70 (Tex.App.—Tyler 1982, no writ).

As to the amendment of the pleadings, James shows no error. Parties may amend their pleadings by filing such pleadings with the clerk at such time as not to operate as a surprise to the opposite party; pleadings offered for filing within seven days of the date of trial shall be filed only after leave of the court is obtained, which leave shall be granted by the court unless there is a showing that such filing will operate as a surprise to the opposite party. Tex.R.Civ.P. 63. Without a showing of surprise, the trial court must grant leave for a party to file the amendment when requested within seven days of trial or thereafter. Greenhalgh v. Service Lloyds Ins. Co., 787 S.W.2d 938, 940 (Tex.1990). Thus, a party’s right to amend under Rule 63 is subject only to the opposing party’s right to show surprise. To reverse a trial court’s ruling allowing pleadings to be amended, an appellant must show that the trial court abused its discretion; to establish abuse of discretion, the complaining party must claim surprise and request a continuance. Louisiana & Arkansas Ry. Co. v. Blakely, 773 S.W.2d 595, 597 (Tex.App.—Texarkana 1989, writ denied). The third amended petition raised no new substantive matters, and because James showed no surprise or prejudice, the trial court is not shown to have abused its discretion in allowing the pleadings to be amended.

With regard to the refusal of the trial court to sever this case from that seeking to terminate Sherman Goodson’s parental rights, the court again is allowed wide discretion. See Cherokee Water Co. v. Forderhause, 641 S.W.2d 522, 525 (Tex.1982); see also Tex.R.Civ.P. 41. The cases against James and Goodson involved common allegations and evidence; in fact, at the crux of the case were sexual acts which the two performed in the presence of the children. James shows no abuse of the trial court’s discretion by its refusal to sever the cases.

EVIDENTIARY RULINGS AND SUFFICIENCY

The trial court erred in several particulars in allowing evidence which should have been excluded. Because the sufficiency of *239 the evidence is related to our harm analysis, these questions are discussed together. The trial court erred in admitting a videotape of the children, hearsay statements made by them to several witnesses, and an opinion as to the truthfulness of the children.

a. The videotape

The Family Code allows for a videotaped statement of a child to be admitted in proceedings like these. 2 This videotape, however, should not have been admitted for two reasons.

Firstly, Tex.Fam.Code Ann. § 11.21(b) (Vernon 1986) provides that the statement must not have been made in response to questioning calculated to lead the child to make a particular statement. 3 By prohibiting leading questions in cases governed by Section 11.21(b)(4), the legislative branch adopted the common-law rule insofar as the uncross-examined videotaped testimony of children under the age of twelve is concerned. Ochs v. Martinez, 789 S.W.2d 949, 956 (Tex.App.—San Antonio 1990, writ denied). Under the strictures of Tex.Fam. Code Ann. § 11.21 (Vernon 1986), questions directed to a child must be open-ended and not suggestive of a response. Id. We conclude that the videotape with these children’s statements should have been excluded because the questioning was calculated to lead the children to a particular statement. 4 The questioning itself was general *241 ly leading. In addition, Sellers’ nonverbal communication, such as her approving, affectionate pats in response to desired answers and her active, demonstrative use of the dolls, coupled with her argumentative refusal to accept undesired answers, contributed to making a particular statement. Thus, the statement should not have been admitted as evidence.

Secondly, the videotaped statement should have been excluded as a sanction for discovery abuse. The Department of Human Services failed to disclose the existence of the videotape in response to a discovery request. The videotape was revealed to James’ attorney only five days before trial. This time was past the discovery deadline. A party who fails to respond or to supplement a response to a discovery request is not entitled to present the undisclosed evidence unless the court finds that good cause existed for the omission. Tex.R.Civ.P. 166b(6), 215(5). 5 The party offering the evidence has the burden of proof to show good cause in the record. See Yeldell v. Holiday Hills Retirement & Nursing Center, Inc., 701 S.W.2d 243, 246- *242 47 (Tex.1985).

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Bluebook (online)
836 S.W.2d 236, 1992 WL 151954, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-v-texas-department-of-human-services-texapp-1992.