In the Interest of J.R., a Child — Abatement Order

Court of Appeals
Tenth Appellate District of Texas
10-26-00378-CV
In the Interest of J.R., a Child
On appeal from the
County Court at Law No. One of Ellis County, Texas
Judge James S. Chapman, presiding
Trial Court No. 117032CCL
PER C URIAM order of the Court.
A B A T E M E N T O R D E R
Appellant, H.B., appealed a judgment that terminated her parental
rights. Subsequently, she filed a request for findings of fact and conclusions of
law. 	Appellant has filed a motion in this Court seeking an abatement of this
appeal for the trial court to enter its findings of fact and conclusions of law.
This Court requested a response from the department as to the department’s
agreement or objection to Appellant’s motion. The department agrees with the
abatement to allow the trial court to enter an amended order adding the
required findings relating to reasonable efforts made to return the child to her
mother, but disagrees with the rest of the motion.

In the Interest of J.R., a Child 	Page 2
In 	her 	motion, 	Appellant 	acknowledges 	that 	the 	trial 	court 	signed
findings of fact and conclusions of law prior to the filing of her motion, but
alleges that she filed a “request for additional/amended findings of fact and
conclusions of law” on the same day as the motion was submitted to this Court.
However, she did not attach a copy of her request to her motion.
Texas Family Code Section 161.001(f) provides that:
(f) In a suit for termination of the parent-child relationship filed by
the Department of Family and Protective Services, the court may
not 	order 	termination 	of 	the 	parent-child 	relationship 	under
Subsection (b)(1) unless the court finds by clear and convincing
evidence and describes in writing with specificity in a separate
section of the order that:
(1) the department made reasonable efforts to return the child to
the parent before commencement of a trial on the merits and
despite those reasonable efforts, a continuing danger remains in
the home that prevents the return of the child to the parent[.]
T EX . FAM. C ODE . § 161.000(f).
The trial court ordered the termination of the parent-child relationship
under Subsection (b)(1), and thus, its order must comport with Texas Family
Code Subsection (f). However, the trial court’s termination order lacks specific
written findings describing with specificity the reasonable efforts made by the
department to return the child to the parent. See id.
Appellant’s motion is granted as to the required findings set forth in this
Order. Accordingly, we order this cause abated and remanded to the trial court

In the Interest of J.R., a Child 	Page 3
to 	enter 	the 	required 	findings 	describing 	with 	sufficient 	specificity 	the
reasonable efforts made to return the child to the parent. See TEX . R. A PP . P.
43.6, 44.4. The trial court is also directed to consider any timely filed request
for additional or amended findings of fact and conclusions of law and may enter
any additional findings it deems proper. 	We express no opinion on whether
additional or amended findings should be entered.
The 	parties 	are 	encouraged 	to 	assist 	the 	trial 	court 	as 	needed 	in
complying with this Order.
These findings must be included in a supplemental clerk’s record to be
forwarded to this court on or before Wednesday, November 4, 2026. This
appeal will be automatically reinstated upon the filing of the supplemental
clerk’s record or on Wednesday, November 4, 2026, whichever is earlier.
ORDER ISSUED and FILED: October 21, 2026
Before Chief Justice Johnson,
Justice Harris, and
Justice Westerfeld
Appeal abated
Motion granted