In the Interest of S.P., Child v. the State of Texas

Fourth Court of Appeals
San Antonio, Texas
MEMORANDUM OPINION

No. 04-25-00412-CV

IN THE INTEREST OF S.P., a Child

From the 150th Judicial District Court, Bexar County, Texas
Trial Court No. 2024PA01182
Honorable Sid L. Harle, Judge Presiding

Opinion by: Lori I. Valenzuela, Justice

Sitting: Rebeca C. Martinez, Chief Justice
Lori I. Valenzuela, Justice
H. Todd McCray, Justice

Delivered and Filed: October 29, 2025

AFFIRMED; MOTION TO WITHDRAW DENIED

Appellant I.P.M. appeals the trial court’s order terminating her parental rights to her child,

S.P. 1 Her court-appointed appellate counsel filed a motion to withdraw and a brief containing a

professional evaluation of the record, concluding there are no arguable grounds for reversal of the

termination order. The brief satisfies the requirements of Anders v. California, 386 U.S. 738

(1967). See In re P.M., 520 S.W.3d 24, 27 n.10 (Tex. 2016) (per curiam) (recognizing that Anders

procedures apply in parental termination cases). Additionally, counsel represents that he provided

I.P.M. with a copy of the brief and the motion to withdraw, advised I.P.M. of her right to review

1
To protect the privacy of the minor child, we use initials or pseudonyms to refer to the child and his biological
mother. TEX. FAM. CODE § 109.002(d); TEX. R. APP. P. 9.8(b)(2).
04-25-00412-CV

the record and file her own brief, and informed I.P.M. how to obtain a copy of the record, providing

her with a form motion for access to the appellate record. We issued an order setting a deadline

for I.P.M. to file a pro se brief. However, I.P.M. did not request the appellate record or file a pro

se brief.

After reviewing the appellate record and appointed counsel’s brief, we conclude no

plausible grounds exist for reversal of the termination order. Accordingly, we affirm the trial

court’s termination order. We deny counsel’s motion to withdraw because it does not show good

cause for withdrawal. See id. at 27 & n.7 (holding that counsel’s obligations in a parental

termination case extend through exhaustion or waiver of all appeals and that withdrawal should be

permitted by a court of appeals “only for good cause”).

Lori I. Valenzuela, Justice

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