In the Interest of K.N.R., a Minor Child

Summary

The Supreme Court of Texas held that a parent’s unpreserved complaint concerning the broad-form submission of termination grounds in a parental-rights termination case was not reviewable on appeal. Relying on In re B.L.D., the court reversed the court of appeals and remanded for further proceedings.

Holdings

1. A party's complaint about a jury charge in a parental-rights termination case is not preserved when the party failed to object to the charge in the trial court, and the court of appeals may not review the unpreserved complaint.

Questions Presented

1. Whether the court of appeals could review Jones's unpreserved complaint that the broad-form submission of alternate termination grounds violated a constitutional right to agreement by ten jurors on each predicate ground.
2. Whether the preservation-of-error rule and due process required appellate review of the unpreserved jury-charge complaint in a parental-rights termination case.

Disposition

reversed_and_remanded