In Re T.A.S.D., a Child v. the State of Texas
CourtTexas Court of Appeals, 4th District (San Antonio)
Date FiledJuly 8, 2026
Docket04-26-00402-CV
StatusPublished
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Full Opinion
Fourth Court of Appeals
San Antonio, Texas
MEMORANDUM OPINION
No. 04-26-00402-CV
IN RE T.A.S.D., a Child
Original Proceeding 1
PER CURIAM
Sitting: Lori I. Valenzuela, Justice
Adrian A. Spears II, Justice
Velia J. Meza, Justice
Delivered and Filed: July 8, 2026
PETITION FOR WRIT OF MANDAMUS DENIED; MOTION FOR EMERGENCY RELIEF
DENIED AS MOOT
Relator, E.D., filed her petition for writ of mandamus, motion to stay enforcement of an
April 18, 2023 custody order, and mandamus record on May 18, 2026. E.D. filed an amended
petition for writ of mandamus on May 19, 2026. Mandamus is an extraordinary remedy, available
only when the relator can show (1) the trial court clearly abused its discretion or violated a duty
imposed by law; and (2) there is no adequate remedy at law, such as an appeal. Walker v. Packer,
827 S.W.2d 833, 839-40 (Tex. 1992) (orig. proceeding). However, when the trial court issues a
void order, the relator need not show that an appellate remedy is inadequate to obtain mandamus
This proceeding arises out of Cause No. 22-03-61760-CV, styled In the Interest of T.A.S.D., a Child, pending in the
1
County Court, Jim Wells County, Texas, the Honorable Rumaldo Solis, Jr presiding.
04-26-00402-CV
relief. In re Sw. Bell Tel. Co., 35 S.W.3d 602, 605 (Tex. 2000) (“[B]ecause the order was void, the
relator need not show it did not have an adequate appellate remedy, and mandamus relief is
appropriate.”).
According to E.D., the trial court lacked jurisdiction to enter an April 18, 2023 custody
order regarding T.A.S.D. because the child had not resided in Texas in the five months prior to the
real party in interest filing his suit affecting the parent-child relationship. “[A] court of this state
has jurisdiction to make an initial child custody decision” if this state “was the home state of the
child within six months before commencement of the proceeding and the child is absent from this
state but a parent or person acting as a parent continues to live in this state.” TEX. FAM. CODE §
152.201(a)(1) (emphasis added).
Having considered the petition, the motion, and the record, this court concludes E.D. has
not shown that she is entitled to the relief sought. Accordingly, the petition for writ of mandamus
is denied. See TEX. R. APP. P. 52.8(a). E.D.’s motion for temporary relief is denied as moot.
Further, the petition for writ of mandamus and the mandamus record each disclose the full
name of a minor child and other sensitive data that is required to be redacted under the Texas Rules
of Appellate Procedure and this court’s local rules. See TEX. R. APP. P. 9.8 and 9.9; 4TH TEX. APP.
(San Antonio) LOC. R. 4.2 (2025). Accordingly, we strike the petition for writ of mandamus and
the mandamus record.
PER CURIAM
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