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This case addresses the due process implications of Section 263.405 of the Texas Family Code, which sets accelerated appellate deadlines for parental rights termination cases. Petitioner Lester Williams, an indigent parent, had his parental rights terminated. His appointed counsel was substituted after the statutory fifteen-day deadline to file a statement of points on which he intended to appeal. Consequently, the trial court denied him an appellate record, deeming his appeal frivolous solely due to the late filing. Drawing on its previous decision in In re J.O.A., the Texas Supreme Court holds that due process prevents denying an appellate record on the sole basis of a late-filed statement of points, particularly when it hinders an indigent parent's ability to raise an ineffective assistance of counsel claim. The Court emphasizes the paramount private interests involved in parental rights cases and finds that the state's interest in expediency does not justify such a restriction. Therefore, the Supreme Court reverses the judgment of the court of appeals and remands the case, instructing that a complete appellate record be prepared and Williams's issues considered as if his statement of points had been timely filed.
In the Interest of B.G. is a workers' compensation case decided in Texas Supreme Court. This case addresses legal issues related to compensation claims, benefits, and court rulings.
It is commonly referenced in legal research involving workers' compensation laws in Texas Supreme Court.
Full Decision Text1 Pages
This case addresses the due process implications of Section 263.405 of the Texas Family Code, which sets accelerated appellate deadlines for parental rights termination cases. Petitioner Lester Williams, an indigent parent, had his parental rights terminated. His appointed counsel was substituted after the statutory fifteen-day deadline to file a statement of points on which he intended to appeal. Consequently, the trial court denied him an appellate record, deeming his appeal frivolous solely due to the late filing. Drawing on its previous decision in In re J.O.A., the Texas Supreme Court holds that due process prevents denying an appellate record on the sole basis of a late-filed statement of points, particularly when it hinders an indigent parent's ability to raise an ineffective assistance of counsel claim. The Court emphasizes the paramount private interests involved in parental rights cases and finds that the state's interest in expediency does not justify such a restriction. Therefore, the Supreme Court reverses the judgment of the court of appeals and remands the case, instructing that a complete appellate record be prepared and Williams's issues considered as if his statement of points had been timely filed.
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