Texas Health and Human Services Commission; Cecile Erwin Young, Executive Commissioner; Laura Castillo, Director of Heightened Monitoring; And Department of Family and Protective Services v. Kenneth Collier, Taneshu Collier, TRELS Home for Children, and TRELS Home LLC

ACCEPTED
15-25-00182-cv
Appellate Docket Number: 15-25-00182-cv FIFTEENTH COURT OF APPEALS
Appellate Case Style: Texas Health and Human Services Commission, et al. AUSTIN, TEXAS
Vs. Kenneth Collier, Taneshu Collier, TRELS Home for Children, and TRELS Home LLC
11/17/2025 3:46 PM
Companion CHRISTOPHER A. PRINE
Case(s): CLERK
Amended/Corrected Statement FILED IN
15th COURT OF APPEALS
DOCKETING STATEMENT (Civil) AUSTIN, TEXAS
Appellate Court: 15th Court of Appeals 11/17/2025 3:46:36 PM
(to be filed in the court of appeals upon perfection of appeal under TRAP 32) A. PRINE
CHRISTOPHER
Clerk
NOTE: Because space for additional parties / attorneys is limited on this form, you can include the information on a separate document. As per TRAP
32.1 and 9.4, please include party’s name and the name, address, email address, telephone number, fax number, if any, and State Bar Number of the
party’s lead counsel. If the party is not represented by an attorney, that party’s name, address, telephone number, fax number should be provided.

I. Appellant II. Appellant Attorney(s) - Continued
Person Organization Lead Attorney Select
Name: TX Health & Human Services Comm., el al; see attached Name:
Pro Se Bar No.
If Pro Se Party, enter the following information: Firm/Agency:
Address: Address 1:
City/State/Zip: Address 2:
Tel. Ext. Fax: City/State/Zip:
Email: Tel. Ext. Fax:
II. Appellant Attorney(s) Email:
Lead Attorney Retained Attorney
Lead Attorney Select
Name: Kelsey Hanson Name:
Bar No. 24096654
Bar No.
Firm/Agency: Office of the Attorney General
Firm/Agency:
Address 1: General Litigation Division Address 1:
Address 2: P.O. Box 12548, Capitol Station
Address 2:
City/State/Zip: Austin/TX/78711 City/State/Zip:
Tel. (737) 224-1244 Ext. Fax: (512) 320-0667
Tel. Ext. Fax:
Email: kelsey.hanson@oag.texas.gov
Email:
Lead Attorney Select
Lead Attorney Select
Name:
Name:
Bar No.
Bar No.
Firm/Agency:
Firm/Agency:
Address 1:
Address 1:
Address 2:
Address 2:
City/State/Zip:
City/State/Zip:
Tel. Ext. Fax:
Tel. Ext. Fax:
Email:
Email:

Page 1 of 11
III. Appellee IV. Appellee Attorney(s) - Continued
Person Organization Lead Attorney Retained Attorney
Name: Kenneth Collier, et al.; see attached Name: Meghan Rudnai
Pro Se Bar No. 24086875
If Pro Se Party, enter the following information: Firm/Agency: Ferguson Law Practice, PLLC
Address: Address 1: 1017 RR 620 S, Ste. 222
City/State/Zip: Address 2:
Tel. Ext. Fax: City/State/Zip: Lakeway/TX/78734
Email: Tel. (512) 996-5407 Ext. Fax:
Email: meghan@fergusonlawpracticc.com
IV. Appellee Attorney(s)
Lead Attorney Retained Attorney Lead Attorney Select

Name: Kyle Ann Ferguson Name:
Bar No. 24065223 Bar No.
Firm/Agency: Ferguson Law Practice, PLLC Firm/Agency:
Address 1: 1017 RR 620 S, Ste. 222 Address 1:
Address 2: Address 2:
City/State/Zip: Lakeway/TX/78734 City/State/Zip:
Tel. (512) 996-5407 Ext. Fax: Tel. Ext. Fax:
Email: kyle@fergusonlawfirm.com Email:

Lead Attorney Retained Attorney Lead Attorney Select

Name: John Ferguson Name:
Bar No. 24066597 Bar No.
Firm/Agency: Ferguson Law Practice, PLLC Firm/Agency:
Address 1: 1017 RR 620 S, Ste. 222 Address 1:
Address 2: Address 2:
City/State/Zip: Lakeway/TX/78734 City/State/Zip:
Tel. (512) 996-5407 Ext. Fax: Tel. Ext. Fax:
Email: john@fergusonlawpractice.com Email:

Page 2 of 11
V. Perfection of Appeal, Judgment and Sentencing
Nature of Case (Subject matter or type of case): Governmenal Immunity
Date Order or Judgment signed: 11/04/2025 Type of Judgment: Interlocutory Order
Date Notice of Appeal filed in Trial Court: 11/03/2025
If mailed to the Trial Court clerk, also give the date mailed:
Interlocutory appeal of appealable order: Yes No
If yes, please specify statutory or other basis on which interlocutory order is appealable (See TRAP 28):
Tex. Civ. Prac. & Rem. Code Sec. 51.014(a)(4) and Tex. Civ. Prac. & Rem. Code Sec. 51.014(a)(8)

Accelerated Appeal (See TRAP 28): Yes No
If yes, please specify statutory or other basis on which appeal is accelerated:
Tex. R. App. P. 28.1(a))

Parental Termination or Child Protection? (See TRAP 28.4): Yes No
Permissive? (See TRAP 28.3): Yes No
If yes, please specify statutory or other basis for such status:

Agreed? (See TRAP 28.2): Yes No
If yes, please specify statutory or other basis for such status:

Appeal should receive precedence, preference, or priority under statute or rule? Yes No
If yes, please specify statutory or other basis for such status:

Does this case involve an amount under $100,000? Yes No
Judgment or Order disposes of all parties and issues? Yes No
Appeal from final judgment? Yes No
Does the appeal involve the constitutionality or the validity of a statute, rule, or ordinance? Yes No
If yes, you must also complete and file the Challenge to Constitutionality of a State Statute form.
If yes, is the Attorney General of Texas a party to the case? Yes No

VI. Actions Extending Time to Perfect Appeal
Motion for New Trial: Yes No If yes, date filed:
Motion to Modify Judgment: Yes No If yes, date filed:
Request for Findings of Fact and Conclusions of Law: Yes No If yes, date filed:
Motion to Reinstate: Yes No If yes, date filed:
Motion under TRCP 306a: Yes No If yes, date filed:
Other: Yes No
If Other, please specify:

Page 3 of 11
VII. Indigency of Party (Attach file stamped copy of Statement and copy of the trial court order.)
Was Statement of Inability to Pay Court Costs filed in the trial court? Yes No
If yes, date filed:
Was a Motion Challenging the Statement filed in the trial court? Yes No
If yes, date filed:
Was there any hearing on appellant’s ability to afford court costs? Yes No
Hearing Date:
Did trial court sign an order under Texas Rule of Civil Procedure 145? Yes No

Date of Order:
If yes, trial court finding: Challenge Sustained Overruled
VIII. Bankruptcy
Has any party to the court’s judgment filed for protection in bankruptcy which might affect this appeal?
Yes No
If yes, please attach a copy of the petition.
Date bankruptcy filed:
Bankruptcy Case Number:

IX. Trial Court and Record
Court: 345th Judicial District Clerk’s Record
County: Travis Trial Court Clerk: ✔ District County
Trial Court Docket No. (Cause No.): Was Clerk’s record requested? ✔ Yes No
D-1-GN-25-004379
If yes, date requested: 11/04/2025
Trial Court Judge (who tried or disposed of the case): If no, date it will be requested:
Name: Hon. Donnie Burgess
Were payment arrangements made with clerk?
Address 1: Travis County Courthouse - 345th Dis.
✔ Yes No Indigent
Address 2: 1700 Guadalupe Street, 10th Flr.
(Note: No request required under TRAP 34.5(a),(b).)
City/State/Zip: Austin/TX/78701
Tel. (512) 854-9374 Ext. Fax:
Email: 345.Submission@traviscountytx.gov

Page 4 of 11
IX. Trial Court and Record - Continued
Reporter’s or Recorder’s Record
Is there a Reporter’s Record? Yes No
Was Reporter’s Record requested? Yes No
If yes, date requested: 10/23/2025
If no, date it will be requested:
Was the Reporter’s Record electronically recorded? Yes No
Were payment arrangements made with the court reporter/court recorder? Yes No Indigent

Court Reporter Court Recorder Court Reporter Court Recorder
Official Substitute Official Substitute
Name: Michelle Williamson Name:
Address 1: 345th District Court - Travis County Address 1:
Address 2: 1700 Guadalupe Street, Courtroom 10-C Address 2:
City/State/Zip: Austin/TX/78701 City/State/Zip:
Tel. (512) 854-9373 Ext. Fax: Tel. Ext. Fax:
Email: michelle.williamson@traviscountytx.gov Email:

X. Supersedeas Bond
Supersedeas bond filed? Yes No
If yes, date filed:
If no, will file? Yes No

XI. Extraordinary Relief
Will you request extraordinary relief (e.g., temporary or ancillary relief) from this Court? Yes No
If yes, briefly state the basis for your request:

Page 5 of 11
XII. Alternative Dispute Resolution/Mediation
(Complete section if filing in the 1st, 2nd, 4th, 5th, 6th, 8th, 10th, 11th, 13th, or 14th Court of Appeals.)
Should this appeal be referred to mediation? Yes No
If no, please specify:
Has this case been through an ADR procedure? Yes No
If yes, who was the mediator?
What type of ADR procedure?
At what stage did the case go through ADR? Pre-Trial Post-Trial Other
If other, please specify:
Type of Case? Governmenal Immunity and Injunction
Give a brief description of the issue to be raised on appeal, the relief sought, and the applicable standard for review, if
known (without prejudice to the right to raise additional issues or request additional relief):

How was the case disposed of?
Summary of relief granted, including amount of money judgment, and if any, damages awarded.
If money judgment, what was the amount? Actual damages:
Punitive (or similar) damages:
Attorney’s fees (trial):
Attorney’s fees (appellate):
Other:
If other, please specify:
Will you challenge this Court’s jurisdiction? Yes No
Does judgment have language that one or more parties “take nothing”? Yes No
Does judgment have a Mother Hubbard clause? Yes No
Other basis for finality:

Page 6 of 11
XII. Alternative Dispute Resolution/Mediation - Continued
(Complete section if filing in the 1st, 2nd, 4th, 5th, 6th, 8th, 10th, 11th, 13th, or 14th Court of Appeals.)
Rate the complexity of the case (use 1 for least and 5 for most complex): 1 2 3 4 5
Please make my answer to the preceding questions known to other parties in this case? Yes No
Can the parties agree on an appellate mediator? Yes No
If yes, please give the name, address, telephone, fax, and email address:
Name:
Address:
Telephone: Ext.
Fax:
Email:
Languages other than English in which the mediator should be proficient:

Name of the person filling out mediation section of docketing statement:

XIII. Related Matters
List any pending or past related appeals before this, or any other Texas Appellate Court, by Court, Docket, and Style.
Court: Select Appellate Court Docket:
Style:
Vs.
Court: Select Appellate Court Docket:
Style:
Vs.
Court: Select Appellate Court Docket:
Style:
Vs.
Court: Select Appellate Court Docket:
Style:
Vs.
Court: Select Appellate Court Docket:
Style:
Vs.
Court: Select Appellate Court Docket:
Style:
Vs.

Page 7 of 11
XIV. Pro Bono Program:
(Complete section if filing in the 1st, 2nd, 3rd, 5th, 7th, 13th or 14th Court of Appeals.)
The Courts of Appeals listed above, in conjunction with the State Bar of Texas Appellate Section Pro Bono Committee
and local Bar Associations, are conducting a program to place a limited number of civil appeals with appellate counsel
who will represent the appellant in the appeal before this Court.
The Pro Bono Committee is solely responsible for screening and selecting the civil cases for inclusion in the Program
based upon a number of discretionary criteria, including the financial means of the appellant or appellee. If a case is
selected by the Committee, and can be matched with appellate counsel, that counsel will take over representation of the
appellant or appellee without charging legal fees. More information regarding this program can be found in the Pro Bono
Program Pamphlet available in paper form at the Clerk's Office or on the Internet at http://www.tex-app.org. If your case
is selected and matched with a volunteer lawyer, you will receive a letter from the Pro Bono Committee within thirty (30)
to forty-five (45) days after submitting this Docketing Statement.
Note: there is no guarantee that if you submit your case for possible inclusion in the Pro Bono Program, the Pro Bono
Committee will select your case and that pro bono counsel can be found to represent you. Accordingly, you should not
forego seeking other counsel to represent you in this proceeding. By signing your name below, you are authorizing the
Pro Bono committee to transmit publicly available facts and information about your case, including parties and
background, through selected Internet sites and Listserv to its pool of volunteer appellate attorneys.
Do you want this case to be considered for inclusion in the Pro Bono Program? Yes No
Do you authorize the Pro Bono Committee to contact your trial counsel of record in this matter to answer questions the
committee may have regarding the appeal? Yes No
Please note that any such conversations would be maintained as confidential by the Pro Bono Committee and the
information used solely for the purposes of considering the case for inclusion in the Pro Bono Program.
If you have not previously filed a Statement of Inability to Pay Court Costs and attached a file-stamped copy of that
Statement, does your income exceed 200% of the U.S. Department of Health and Human Services Federal Poverty
Guidelines? Yes No
These guidelines can be found in the Pro Bono Program Pamphlet as well as on the internet at
http://aspe.hhs.gov/poverty/06poverty.shtml.
Are you willing to disclose your financial circumstances to the Pro Bono Committee? Yes No
If yes, please attach a Statement of Inability to Pay Court Costs completed and executed by the appellant or appellee.
Sample forms may be found in the Clerk's Office or on the internet at http://www.tex-app.org. Your participation in
the Pro Bono Program may be conditioned upon your execution of a Statement under oath as to your financial
circumstances.

Give a brief description of the issues to be raised on appeal, the relief sought, and the applicable standard of review, if
known (without prejudice to the right to raise additional issues or request additional relief; use a separate attachment, if
necessary).

Page 8 of 11
XV. Fifteenth Court of Appeals Jurisdiction
Effective 9/1/24, certain cases filed with this court must be transferred to the new Fifteenth Court of Appeals (See SB
1045, 88th Legislature, Regular Session). To assist the court in the orderly transfer or cases, please complete the
following information.
Does this appeal involve a matter brought by or against the state or a board, commission, department, office, or other
agency in the executive branch of the state government, including a university system or institution of higher education
as defined by Section 61.003, Education Code, or by or against an officer or employee of the state or a board,
commission, department, office, or other agency in the executive branch of the state government arising out of that
officer ’s or employee ’s official conduct? Yes No
If the answer is yes, does this appeal involve:
a proceeding brought under the Family Code and any related motion or proceeding;
a proceeding brought under Chapter 7B or Article 17.292, Code of Criminal Procedure;
a proceeding brought against a district attorney, a criminal district attorney, or a county attorney with criminal
jurisdiction;
a proceeding relating to a mental health commitment;
a proceeding relating to civil asset forfeiture;
a condemnation proceeding for the acquisition of land or a proceeding related to eminent domain;
a proceeding brought under Chapter 101, Civil Practice and Remedies Code;
a claim of personal injury or wrongful death;
a proceeding brought under Chapter 125, Civil Practice and Remedies Code, to enjoin a common nuisance;
a proceeding brought under Chapter 55, Code of Criminal Procedure;
a proceeding under Chapter 22A, Government Code;
a proceeding brought under Subchapter E-1, Chapter 411, Government Code;
a proceeding brought under Chapter 21, Labor Code;
a removal action under Chapter 87, Local Government Code;
a proceeding brought under Chapter 841, Health and Safety Code;

XVI. Signature
11/17/2025
Signature of counsel (or Pro Se Party) Date
Kelsey Hanson 24096654
Printed Name State Bar No.
/s/ Kelsey Hanson Kelsey Hanson
Electronic Signature (Optional) Name

XVII. Certificate of Service
The undersigned counsel certifies that this Docketing Statement has been served on the following lead counsel for all
parties to the Trial Court’s Order or Judgment as follows on:
/s/ Kelsey Hanson
Signature of counsel (or Pro Se Party) Electronic Signature (Optional)

24096654
State Bar No.

Certificate of Service Requirements (TRAP 9.5(e)): A certificate of service must be signed by the person who made the service and
must state:
(1) the date and manner of service;
(2) the name and address of each person served, and
(3) if the person served is a party’s attorney, the name of the party represented by the attorney.

Page 9 of 11
Please enter the following for each person served:
Date Served: 11/17/2025 Date Served:
Manner Served: eServe Manner Served: Select
Name: Kyle Ferguson Name:
Bar No. 24065223 Bar No.
Firm/Agency: Ferguson Law Practice, PLLC Firm/Agency:
Address 1: 1017 RR 620 S, Ste. 222 Address 1:
Address 2: Address 2:
City/State/Zip: Lakeway/TX/78734 City/State/Zip:
Tel. (512) 996-5407 Ext. Fax: Tel. Ext. Fax:
Email: kyle@fergusonlawfirm.com Email:
Party: Appellees Party:

Date Served: 11/17/2025 Date Served:
Manner Served: eServe Manner Served: Select
Name: John Ferguson Name:
Bar No. 24066597 Bar No.
Firm/Agency: Ferguson Law Practice, PLLC Firm/Agency:
Address 1: 1017 RR 620 S, Ste. 222 Address 1:
Address 2: Address 2:
City/State/Zip: Lakeway/TX/78734 City/State/Zip:
Tel. (512) 996-5407 Ext. Fax: Tel. Ext. Fax:
Email: john@fergusonlawfirm.com Email:
Party: Appellees Party:

Date Served: 11/17/2025
Manner Served: eServe
Name: Meghan Rudnai
Bar No. 24086875
Firm/Agency: Ferguson Law Practice, PLLC
Address 1: 1017 RR 620 S, Ste. 222
Address 2:
City/State/Zip: Lakeway/TX/78734
Tel. (512) 996-5407 Ext. Fax:
Email: meghan@fergusonlawfirm.com
Party: Appellees

Page 10 of 11
Please enter the following for each person served that is not an attorney for a party:
Date Served: Date Served:
Manner Served: Select Manner Served: Select
Name: Name:
Address 1: Address 1:
Address 2: Address 2:
City/State/Zip: City/State/Zip:
Tel. Ext. Tel. Ext.
Fax: Fax:
Email: Email:

Date Served: Date Served:
Manner Served: Select Manner Served: Select
Name: Name:
Address 1: Address 1:
Address 2: Address 2:
City/State/Zip: City/State/Zip:
Tel. Ext. Tel. Ext.
Fax: Fax:
Email: Email:

Date Served: Date Served:
Manner Served: Select Manner Served: Select
Name: Name:
Address 1: Address 1:
Address 2: Address 2:
City/State/Zip: City/State/Zip:
Tel. Ext. Tel. Ext.
Fax: Fax:
Email: Email:

Page 11 of 11
Appellants

1) Texas Health and Human Services Commission
2) Cecile Erwin Young in her individual capacity and capacities as Executive Commissioner
3) Laura Castillo, in her individual capacity and capacities as Director of Heightened
Monitoring
4) Department of Family and Protective Services
Appellees

1) Kenneth Collier
2) Taneshu Collier
3) TRELS Home for Children
4) TRELS Home LLC
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Kelsey Hanson on behalf of Kelsey Hanson
Bar No. 24096654
kelsey.hanson@oag.texas.gov
Envelope ID: 108137106
Filing Code Description: Docketing Statement
Filing Description: Appellants Docketing Statement
Status as of 11/17/2025 3:53 PM CST

Associated Case Party: TEXAS HEALTH AND HUMAN SERVICES COMMISSION

Name BarNumber Email TimestampSubmitted Status

Chelsea Goodman chelsea.goodman@oag.texas.gov 11/17/2025 3:46:36 PM SENT

Kelsey Hanson kelsey.hanson@oag.texas.gov 11/17/2025 3:46:36 PM SENT

Associated Case Party: KENNETH COLLIER

Name BarNumber Email TimestampSubmitted Status

Kyle Ferguson kyle@fergusonlawpractice.com 11/17/2025 3:46:36 PM SENT

John Ferguson john@fergusonlawpractice.com 11/17/2025 3:46:36 PM SENT

Meghan Rudnai meghan@fergusonlawpractice.com 11/17/2025 3:46:36 PM SENT