In the Interest of J.M.L.H, a Child v. Department of Family and Protective Services

Opinion issued January 8, 2026.

In The

Court of Appeals
For The

First District of Texas
————————————
NO. 01-25-00539-CV
———————————
IN THE INTEREST OF J.M.L.H., A CHILD

On Appeal from the 315th District Court
Harris County, Texas
Trial Court Case No. 2024-00721J

MEMORANDUM OPINION

In this accelerated appeal, Mother challenges the trial court’s order

terminating her parental rights to her child, J.M.L.H.1 Mother argues on appeal that

(1) the evidence is legally and factually insufficient to support the trial court’s

finding that the Department of Family and Protective Services (the Department)

1
We refer to the parties using pseudonyms. See TEX. R. APP. P. 9.8(b)(2).
made reasonable efforts to return J.M.L.H. to Mother through a surrogate and

(2) the due process rights of Mother and one of J.M.L.H.’s potential fathers were

violated because the Department failed to search for or serve the potential father in

advance of trial. We affirm.

Background

This appeal concerns J.M.L.H., a child who was under two years old at the

time of trial.

A. J.M.L.H.’s Mother and Father

Mother has four children including J.M.L.H. J.M.L.H.’s three elder siblings

live with Mother’s aunt.

Mother has a history of mental illness, with diagnoses that include anxiety,

bipolar I disorder, mood disorder, depression, suicidal ideation, and psychosis, as

well as schizoaffective disorder and/or schizophrenia.2 Mother also has a history of

substance abuse, and her medical records indicate a possible relation between at

least some of her mental health and substance abuse issues. Mother has been

diagnosed as abusing cocaine and ecstasy.

Mother’s criminal history includes:

• An indictment in Georgia on two pending counts of cruelty to children in the
first degree, stemming from charges that Mother left her four-year-old child
in a hotel room without supervision and deprived the child of necessary

2
Mother testified that she has been diagnosed with schizoaffective disorder and not
schizophrenia.

2
sustenance to the extent that the child was malnourished and the child’s
health and well-being were jeopardized;3

• A conviction of misdemeanor terroristic threat with the intent to place the
complainant in fear of imminent serious bodily injury;

• A felony charge of aggravated assault with a deadly weapon;

• A felony charge of assault on a police officer;

• A felony charge of retaliation;

• A felony charge of harassment of a public servant; and

• A felony charge of assault on a contracted employee of the Harris County
Jail.

The Department caseworker assigned to the case testified at trial that Mother had

also threatened the caseworker on multiple occasions, accusing the caseworker of

having removed J.M.L.H. from Mother without cause. For example, Mother

“texted [the caseworker] a few times, stating that [the caseworker] was going to

lose [her] . . . job and [her] life.”

Mother believes that J.M.L.H.’s father could be one of four men, including

Alleged Father 1 and Alleged Father 2. The fourth man is a stranger who sexually

assaulted Mother.

3
Mother testified that she left the child in the hotel room alone for 14 hours, but had
asked the hotel’s manager to keep an eye on the child. Mother also stated that the
child had access to snacks and knew how to heat up food in the microwave.

3
The caseworker testified that, at the start of the Department’s investigation,

the only information the Department had regarding the identity of J.M.L.H.’s

father was the name of Alleged Father 1. In her search for Alleged Father 1, the

caseworker “called possible relatives,” searched the Georgia Department of

Corrections, spoke with the Georgia District 3 Attorney’s Office, and visited a

last-known location of Alleged Father 1. She was unable to make contact with

Alleged Father 1, and Alleged Father 1 did not make contact with the Department.

The caseworker spoke with Alleged Father 1’s ex-wife, but the ex-wife had not

spoken to Alleged Father 1 for about two years. J.M.L.H.’s guardian ad litem

testified that Alleged Father 1 had not responded to attempts to contact him, had

not visited J.M.L.H., had not made any provisions for J.M.L.H., and had not

inquired as to her well-being. Mother has twice denied that Alleged Father 1 is

J.M.L.H.’s father.

The caseworker testified that, shortly before trial, Mother had identified a

second potential father, Alleged Father 2.4 However, Mother had provided just

Alleged Father 2’s name and, though she said she would also provide a phone

number for him, did not provide the phone number. While Alleged Father 2’s name

is somewhat unique, the caseworker did not make any efforts to locate him based

just on his name.
4
Mother testified that she provided the name of Alleged Father 2 two weeks before
trial.

4
B. J.M.L.H.’s Removal

The caseworker testified that the Department began its investigation when

J.M.L.H. was around two weeks old. Mother was living at a shelter called Mission

of Yahweh at the time, “experiencing some postpartum” depression, “using

substances such as methamphetamines,” and “behaving in a concerning way.”5 The

Department received a referral alleging neglectful supervision of two-week-old

J.M.L.H. by Mother. On the day of the referral, Mother stated that she could not

“have [J.M.L.H.] anymore” and that she wanted to “give the baby to her aunt in

Georgia.” Mother asked J.M.L.H. if she wanted to go to Georgia, and claimed that

J.M.L.H., who was too young to speak, had responded that she did not want to go

to Georgia. The Department’s Child Protective Services (CPS) division’s

investigation concluded that there was “reason to believe” at least one allegation of

neglectful supervision by Mother.

5
According to the Department, Mother’s concerning behavior included: (1) not
cooperating with the Department’s investigation; (2) trying to hide J.M.L.H. from
the Department, (3) behaving “in crisis”; (4) stating that she “wanted to go get
raped by the father of [J.M.L.H.] again so that she [could] get pregnant by the
white rapist white man outside”; (5) crying and yelling profanities while on the
floor; (6) “stating that she needed to pray as she attempted to evade law
enforcement”; (7) stating that she could “only deal with white policemen” and that
her rights had been violated when, she claimed, “every race was sent except a
white police officer”; and (8) stating that “there [was] nothing the law [could] do
to her” because she had renounced her citizenship and J.M.L.H. “[did] not have a
name or foot prints.”

5
C. Difficulties Communicating with Mother

The caseworker testified that, after J.M.L.H.’s removal, the caseworker had

difficulties communicating with Mother. Initially, Mother wanted to speak to the

Department only through Mother’s attorney. Later, Mother at times had no phone

service. Mother’s threats to the caseworker were another obstacle. And at some

point later, Mother was incarcerated for a couple of months.

J.M.L.H.’s guardian ad litem also testified that Mother had initially

requested that the guardian ad litem contact Mother only through Mother’s

attorney. More recently, however, the guardian ad litem had been able to visit

Mother at the county jail.

D. Mother’s Family Plan and Visitations

The Department prepared a “Family Plan” for Mother with the goal of

reunifying Mother and J.M.L.H. Among other things, the Family Plan required that

Mother maintain stable housing; verify her employment and income; maintain

contact with the Department; avoid criminal activity; and undergo a substance

abuse assessment, psychiatric evaluation, and psychological evaluation.

Mother had not completed any of the Family Plan requirements by the time

of her incarceration. The caseworker was unable to determine whether Mother

completed any of the Family Plan requirements subsequent to her incarceration.

Mother attended a substance abuse program but did not provide a certificate of

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completion. Mother did not complete the substance abuse assessment. Mother

testified she had not completed the psychiatric evaluation or psychological

evaluation included in her Family Plan, but stated that she had received a

psychiatric evaluation in connection with J.M.L.H.’s removal. Similarly, while she

had not completed a parenting class as required by her Family Plan, she had

attended parenting classes in the past.

To the caseworker’s knowledge, Mother had not seen J.M.L.H. since

J.M.L.H. was removed from her care. The trial court suspended any visits in May

2024, stating: “Due to [Mother’s] behavior at the CPS office visit, the Court

suspends visitation . . . until such time when [Mother] demonstrates sobriety, is in

compliance with all recommendations from a mental health provider, and is

actively engaged in services with the Department.” (Emphasis in original.) The

caseworker’s understanding was that there had been no visitations because Mother

“showed up to a potential visit with J.M.L.H. and was able to bypass security

guards and get into a secured area,” where Mother “caused chaos by throwing

staplers and phones.” The caseworker testified that, after Mother’s visitations with

J.M.L.H. were suspended, Mother had made no efforts to try to keep in contact

with J.M.L.H. through the caseworker.

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E. Mother’s Circumstances at Time of Trial

At the time of trial, Mother was still incarcerated. The caseworker had

visited Mother on a monthly basis in the Harris County Jail. At each visit, the

caseworker would ask Mother for the names of her family members. Up until the

last two of the caseworker’s monthly visits before trial, Mother refused to provide

those names. Up until that time, Mother had not always sought a relationship with

J.M.L.H.

In the two months prior to trial, Mother’s demeanor had “changed a lot.”

Mother stated that she had been taking her medications, and the caseworker could

“tell a difference” when speaking to Mother. Though not all of Mother’s

concerning behaviors were gone, the caseworker had seen improvement. Mother

had told the caseworker that Mother was going to complete in jail those of the

Family Plan’s requirements she could. Mother also for the first time shared the

names of family members. At the time of trial, the caseworker’s understanding was

that Mother might soon be moved from jail to a drug rehabilitation program.

According to the Department, at the time of trial, Mother had not been able

to demonstrate that she was employed and able to provide a safe and stable home

for J.M.L.H. The Department had concerns about Mother’s ability to address her

own psychological needs. Mother had not been able to demonstrate that she could

maintain her own mental health. Mother’s medical records demonstrated that,

8
during her incarceration, she had not always complied with her prescriptions for

medications, had tried to overdose on her medication,6 and had engaged in

self-harm.7 At the time of trial, the Department thus still had concerns regarding

Mother’s ability to care for J.M.L.H. physically, financially, and emotionally if the

two were reunited. As such, the Department’s concurrent goals at the time of trial

were for J.M.L.H. to be adopted by a relative or non-relative.

J.M.L.H.’s guardian ad litem testified at trial that Mother had been unable to

demonstrate that she was able to meet J.M.L.H.’s basic needs. Mother was unable

to rectify the conditions that led to J.M.L.H.’s removal, to earn an income or

otherwise provide financially for J.M.L.H., to provide stable housing for J.M.L.H.,

or to provide permanency for J.M.L.H. The guardian ad litem had concerns

regarding Mother’s drug use and criminal activity. The guardian ad litem favored

termination of Mother’s parental rights.

Mother’s hope at the time of trial was that J.M.L.H. could be placed in a

“healthy environment” with a relative or family friend. Mother had at times sought

to have a relationship with J.M.L.H. The Department remained open to J.M.L.H.’s

being adopted by a relative. A possible placement with Mother’s aunt had been

6
Mother testified that the incident referenced involved her snorting a medicine she
was prescribed for seizures because she felt a seizure coming on.
7
The Department stated at trial that Mother “attempted to jump off the top bunk as
recently as February 2025.”

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rejected based on concerns regarding the aunt’s already having five or six children

in her home (including J.M.L.H.’s three siblings), lacking the financial means to

support an additional child, and lacking a support system. The Department was

investigating a possible placement with one of Mother’s sisters based on a

suggestion by Mother a few days before trial. However, while J.M.L.H.’s guardian

ad litem believed there was value in J.M.L.H.’s knowing her biological family, the

guardian ad litem did not believe there was value in exploring further the option of

a placement with Mother’s sister.

F. J.M.L.H.’s Circumstances at Time of Trial

At the time of trial, J.M.L.H. had been living with a foster mother—the same

foster mother with whom J.M.L.H. had been initially placed when she was

removed from Mother’s care—for about a year. The placement was Foster

Mother’s first. Foster Mother testified at trial that, while it is just she and J.M.L.H.

in her home, J.M.L.H.’s support system includes Foster’s Mother’s “strong

community of friends and family that are in [Foster Mother’s] life.” Foster

Mother’s mother, who visits frequently from out of state, is Department-approved

to stay with J.M.L.H. Foster Mother noted that J.M.L.H.’s teachers at the daycare

J.M.L.H. attends also love J.M.L.H.

Foster Mother described J.M.L.H. as follows:

She is . . . really starting to become independent. She enjoys being
silly. She likes to make people laugh. She is also very affectionate. So,

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when there is someone she has an attachment to, whether it’s a friend
or family member, she loves to give them hugs and kisses. She likes
to make animal sounds. She likes to run around in our yard and she is
-- oh, and she loves reading books. So, we read books, like, all the
time, about 20 minutes a day. It’s, like, one of her favorite things to
do.

Foster Mother testified that she “would love to” adopt J.M.L.H. and “be her mom

forever.” Foster Mother would like to see J.M.L.H. “grow up to have a community

that loves her and friends and family” and to “have every opportunity to seek an

education to pursue her interests [and] follow her dreams.” Foster Mother was

confident that she could meet J.M.L.H.’s needs into the future.

When the Department caseworker first contacted Foster Mother after the

placement, Foster Mother was “very welcoming.” According to the caseworker, by

the time of trial, Foster Mother had bonded with J.M.L.H. and exhibited caregiving

skills. Foster Mother took J.M.L.H. to doctors’ appointments and stayed in contact

with the Department regarding J.M.L.H.’s care. Foster Mother also had a support

system.

Both the caseworker and J.M.L.H.’s guardian ad litem testified that Foster

Mother was meeting all of J.M.L.H.’s basic needs. J.M.L.H. was “well taken care

of” under Foster Mother’s care. Foster Mother provided J.M.L.H. a “drug-free”

and “safe and stable environment” in which J.M.L.H. has a routine and frequently

attends Department-approved daycare. Foster Mother provided J.M.L.H. with a

crib, highchair, and car seat.
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J.M.L.H. has been with Foster Mother since she was two weeks old, and

Foster Mother’s home is the only home J.M.L.H. has known. J.M.L.H. was doing

“very well” and “thriving” with Foster Mother, and neither the Department nor the

guardian ad litem had any concerns about the placement. The guardian ad litem

recommended at trial that J.M.L.H. stay in her current placement. “Everything

appear[ed] to be going really well.” J.M.L.H. had a “healthy, strong bond” with

Foster Mother and was doing well in daycare. J.M.L.H. was developmentally on

target. J.M.L.H. was loved by everyone, was walking, and was advancing in her

milestones. J.M.L.H. was attached to Foster Mother and “fe[lt] loved” by Foster

Mother. The caseworker believed that J.M.L.H.’s staying with Foster Mother was

in J.M.L.H.’s best interest because J.M.L.H. was “taken care of,” “loved,” and

“supported.”

G. Mother’s Trial Testimony

Mother testified at trial that she loved J.M.L.H. and did not want her parental

rights terminated. She asked the trial court to leave J.M.L.H. with Foster Mother

for the time being, while Mother is in custody. But she asked the trial court not to

terminate her parental rights, and to permit the Department to explore Mother’s

sister and the man she believed to be J.M.L.H.’s father—Alleged Father 2, whose

name she had provided to the caseworker shortly before trial—as potential

caregivers to leave open the possibility that Mother could regain custody of

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J.M.L.H. after the completion of her deferred adjudication program. Alleged

Father 2 currently lives in Louisiana, but has a townhome in Georgia.

Mother had begun to take her medicine more frequently, noting that she

previously “might have missed . . . eight months, ten days total.” Complying with

her medication has made Mother feel better. She testified that she was aware of

community resources that are available to help her with any future mental health

struggles, and knows to call 2-1-1 or a crisis hotline if necessary. Mother stated at

trial that she believed that, with the benefit of the parenting and substance abuse

classes she had taken, she is more equipped to respond to challenges than she was

previously.

Mother stated that she had been substance-free for two years. While in

custody, Mother had participated in a drug treatment program, but was removed

from that program after a 45-day period of sobriety. During the program, Mother

learned anger management, not to use drugs as a coping mechanism, and to avoid

individuals who use drugs. Mother noted that her felony charge of Aggravated

Assault with a Deadly Weapon occurred before she had learned about anger

management and coping skills. She now better understands her own behavior and

how to proceed moving forward. She stated that her behaviors have changed, as

well as her understanding of the severity of those behaviors.

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Mother testified that she would like an opportunity to reunite with J.M.L.H.

Mother was working at a hair boutique—a type of work she had done previously.

Mother believed she could make enough money at the hair boutique to provide for

herself and J.M.L.H. Mother’s support system included her older sister, with whom

Mother had contact while in custody, and a woman who, at least for a time, served

as a foster mother for Mother’s other daughter.

Mother stated that, after she was released from custody, she planned to live

with J.M.L.H.’s father and his sister. He had been working a warehouse job for

three years, and Mother believed there would be enough space in the home for her

and J.M.L.H. Mother planned to enroll J.M.L.H. in daycare, and would also have

assistance from the support system she had mentioned.

H. Trial Court Judgment

On June 25, 2025, the trial court terminated Mother’s parental rights under

subsections 161.001(b)(1)(D), (E), (N), and (O) of the Texas Family Code, and

found that the termination of Mother’s parental rights was in J.M.L.H.’s best

interest under subsection 161.001(b)(2). Under section 161.002 of the Texas

Family Code, the trial court also terminated the parent-child relationship, “if any

exists,” between J.M.L.H. and Alleged Father 1 and between J.M.L.H. and

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“respondent father unknown.” The “respondent father unknown” appears to have

been a reference to the stranger who sexually assaulted Mother.8

Sufficiency of the Evidence

The first of Mother’s two issues on appeal is her claim that there is legally

and factually insufficient evidence supporting the trial court’s finding under

subsection 161.001(b)(1)(N)(i) of the Family Code that the Department made

reasonable efforts to return J.M.L.H. to Mother.

A. Standard of Review

In a case to terminate parental rights under section 161.001 of the Texas

Family Code, the Department must establish that (1) the parent committed one or

more of the enumerated acts or omissions justifying termination and

(2) termination is in the best interest of the child. TEX. FAM. CODE § 161.001(b).

Only one predicate finding under subsection 161.001(b)(1) is necessary to support

a judgment of termination when there is also a finding that termination is in the

child’s best interest. In re A.V., 113 S.W.3d 355, 362 (Tex. 2003). The Department

must prove both elements—i.e., both the statutorily prescribed predicate finding(s)

and that termination is in the child’s best interest—by clear and convincing

evidence. In re E.N.C., 384 S.W.3d 796, 803 (Tex. 2012). The Family Code

8
The Department first sought the termination of the parental rights of an
“unknown” father over a year before trial. Mother testified that she identified
Alleged Father 2 as J.M.L.H.’s potential father two weeks before trial.

15
defines “clear and convincing evidence” as “the measure or degree of proof that

will produce in the mind of the trier of fact a firm belief or conviction as to the

truth of the allegations sought to be established.” TEX. FAM. CODE § 101.007.

When assessing the legal sufficiency of the evidence in a termination

proceeding, we consider all evidence in the light most favorable to the trial court’s

finding and decide “whether a reasonable trier of fact could have formed a firm

belief or conviction that its finding was true.” In re J.F.C., 96 S.W.3d 256, 266

(Tex. 2002); see also City of Keller v. Wilson, 168 S.W.3d 802, 817 (Tex. 2005)

(discussing elevated standard of review in parental termination cases). We assume

that any disputed facts were resolved in favor of the finding if a reasonable

factfinder could have done so. J.F.C., 96 S.W.3d at 266. When “no reasonable

factfinder could form a firm belief or conviction” that the matter on which the

Department bears the burden of proof is true, we “must conclude that the evidence

is legally insufficient.” Id. In reviewing the evidence’s factual sufficiency, we

consider the entire record, including disputed evidence. Id. The evidence is

factually insufficient if, considering the entire record, the disputed evidence that a

reasonable factfinder could not have resolved in favor of the finding is so

significant that the factfinder could not reasonably have formed a firm belief or

conviction. Id.

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We give due deference to the factfinder’s findings, and we cannot substitute

our own judgment for that of the factfinder. See In re H.R.M., 209 S.W.3d 105, 108

(Tex. 2006) (per curiam). The factfinder is the sole arbiter when assessing the

credibility and demeanor of witnesses. See id. at 109.

B. Analysis

As noted above, only one predicate finding under subsection 161.001(b)(1)

is necessary to support a judgment of termination when there is also a finding that

termination is in the child’s best interest. A.V., 113 S.W.3d at 362. Because Mother

does not challenge the sufficiency of the evidence supporting the trial court’s

predicate findings under subsections 161.001(b)(1)(D), (E), and (O) of the Family

Code or the trial court’s finding that termination was in J.M.L.H.’s best interest,

we need not consider whether sufficient evidence supports the trial court’s finding

under subsection 161.001(b)(1)(N). See A.V., 113 S.W.3d at 362 (in appeal in

which appellant did not challenge trial court’s predicate finding under subsection

161.001(b)(1)(Q), holding that supreme court did not need to consider whether trial

court’s predicate finding under another subsection was supported by factually and

legally sufficient evidence for termination); Fletcher v. Dep’t of Family &

Protective Services, 277 S.W.3d 58, 64 (Tex. App.—Houston [1st Dist.] 2009, no

pet.) (in appeal in which appellant did not challenge trial court’s possible predicate

finding under subsection 161.001(b)(1)(N), holding that appellate court could not

17
consider “either the challenged grounds or the unchallenged ground and ha[d] no

choice but to overrule the challenges that the appellant ha[d] chosen to assert”); see

also In re A.B.-G., No. 01-24-00509-CV, 2024 WL 4982500, at *11–12 (Tex.

App.—Houston [1st Dist.] Dec. 5, 2024, pet. denied) (mem. op.) (holding that rule

requiring appellate court to review trial court’s predicate findings under

subsections 161.001(b)(1)(D) and (E) if challenged, even where another ground is

sufficient for termination, does not apply when findings under (D) and (E) are not

challenged).

We overrule Mother’s first issue.

Failure to Serve Alleged Father 2

The second of Mother’s two issues on appeal is her claim that the due

process rights of Mother and those of one of J.M.L.H.’s potential fathers—Alleged

Father 2—were violated because the Department failed to search for or serve

Alleged Father 2 in advance of trial. As noted above, Mother testified that she

identified Alleged Father 2 as a potential father of J.M.L.H. two weeks before trial.

Mother told the caseworker that Mother would provide his phone number, but then

failed to do so. The caseworker did not make any efforts to locate Alleged Father 2

based just on his name.

Mother argues that Alleged Father 2’s due process rights were violated, and

that “the trial court erred in rendering a termination order,” because the statutory

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prerequisites for the termination of the rights of an alleged biological father were

not met as to Alleged Father 2. See TEX. FAM. CODE § 161.002. However, the trial

court’s judgment makes no reference to Alleged Father 2. While the trial court

terminated the parent-child relationship, “if any exists,” between J.M.L.H. and

“respondent father unknown,” Alleged Father 2 was not “unknown.” When Mother

first disclosed Alleged Father 2 as J.M.L.H.’s potential father, two weeks before

trial, she also disclosed his name. The Department had sought termination of the

parental rights of an “unknown” father—presumably the man who sexually

assaulted Mother—beginning over a year prior to trial. Moreover, even if the trial

court’s judgment could be read as terminating the parental rights of Alleged

Father 2, Mother does not have standing to challenge that termination. See In re

K.D.T., No. 14-22-00224-CV, 2022 WL 3093384, at *4 n.1 (Tex. App.—Houston

[14th Dist.] Aug. 4, 2022, pet. denied) (mem. op.) (holding that mother had no

standing to challenge termination of father’s parental rights).

Mother asserts that the “parents’” due process rights were violated because

the Department failed to search for or serve Alleged Father 2 in advance of trial.

While she uses the plural possessive, presumably to also reference her own due

process rights, she has not identified or briefed any alleged violation of her own

due process rights. The rules of appellate procedure contain specific requirements

for briefing, including briefing in appeals from final decrees terminating a parent’s

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parental rights to their child. See TEX. R. APP. P. 38.1(f) (brief must state all issues

presented for review), (h) (brief must contain clear summary of arguments),

(i) (brief must contain clear argument for contentions made with appropriate

citations to authority and record); see also In re D.J.W., 394 S.W.3d 210, 223 (Tex.

App.—Houston [1st Dist.] 2012, pet. denied) (rejecting under rule 38.1(i) mother’s

challenge to legal and factual sufficiency of finding under section 161.001, noting

her brief contained no legal argument in support of those points); In re K.C.B., 280

S.W.3d 888, 896 (Tex. App.—Amarillo 2009, pet. denied) (rejecting under rule

38.1(i) mother’s challenge to finding under section 161.001, noting her brief

contained no analysis of relevant facts or law). To the extent Mother had a

complaint regarding an alleged violation of her own due process rights, she was

required, among other things, to state concisely her complaint, provide succinct

and clear argument for why her complaint has merit in fact and in law, and cite and

apply authorities applicable to the lodged complaint along with appropriate record

references. See TEX. R. APP. P. 38.1(f), (h), (i). By failing to adequately brief her

claim that her due process rights were violated by the Department’s failure to

search for or serve Alleged Father 2 in advance of trial, Mother has waived this

issue for appellate review. Even if this issue were properly before us, a party

generally lacks standing to assert a due process violation based on improper

service on another party. In re Guardianship of V.A., 390 S.W.3d 414, 418 (Tex.

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App.—San Antonio 2012, pet. denied); see also Lemieux v. Harley, No.

02-24-00009-CV, 2024 WL 3282209, at *4 (Tex. App.—Fort Worth July 3, 2024,

no pet.) (mem. op.) (holding that guardian grandparents had no due process claim

based on alleged failure to properly serve citation on ward in guardianship case

that terminated their guardianship; reasoning that, while guardians may have been

aggrieved by decision, they were not personally prevented from appearing and

meaningfully participating in proceeding).

We thus overrule Mother’s second issue.

Conclusion

We affirm the trial court’s decree of termination.

Amparo “Amy” Guerra
Justice

Panel consists of Justices Guerra, Caughey, and Dokupil.

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