in Re H.T.M.T., a Minor, 13-15-00328-CV

Relators Phung Thi Bach Tran, Tien Thi Pham, and Khuong Nguyen sought a writ of mandamus to vacate a county court’s "Order for Temporary Guardianship of the Person Pending Contest" and "Order for Possession and Visitation."
Relators argued the County Court at Law No. One of Victoria County lacked jurisdiction because a suit affecting the parent–child relationship (SAPCR) had previously been filed in the 267th District Court of Victoria County.
The Court of Appeals solicited and received responses from real party in interest Donna Scott, attorney ad litem Rodney Durham, guardian ad litem Pamela Orsak, and temporary guardian Diane Kliem.
The opinion summarizes the legal standard for mandamus: relators must show (1) trial-court abuse of discretion and (2) lack of an adequate appellate remedy; however, void orders may be attacked regardless of appellate adequacy.
After considering the petition, responses, and law, the Court concluded relators did not meet their heavy burden for mandamus and therefore lifted the stay and denied relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the county court had jurisdiction over guardianship while a SAPCR was pending in district court	County court lacked subject-matter jurisdiction because a prior SAPCR was pending in district court	Respondents implicitly contend relators failed to prove lack of jurisdiction or abuse sufficient for mandamus	Court denied mandamus; relators did not meet burden to show jurisdictional defect warranting mandamus
Whether mandamus relief requires both abuse of discretion and lack of adequate appellate remedy	Relators argued immediate relief was necessary and appeal was inadequate	Respondents argued relators failed to establish both prerequisites	Court applied the two-prong mandamus standard and found relators did not satisfy it
Whether the orders were void (subject to mandamus even if appeal exists)	Relators implied the orders were void for lack of jurisdiction	Respondents argued orders were not shown to be void	Court did not find the orders void and denied mandamus (not persuaded jurisdictional defect met void standard)
Whether equitable principles affect mandamus issuance	Relators relied on urgency and equity to justify mandamus	Respondents relied on ordinary mandamus standards and procedural posture	Court noted equitable principles guide mandamus issuance but nonetheless denied relief under governing precedent

In re Prudential Ins. Co. of Am., 148 S.W.3d 124 (Tex. 2004) (mandamus prerequisites: abuse of discretion and no adequate appellate remedy)
In re CSX Corp., 124 S.W.3d 149 (Tex. 2003) (relator bears heavy burden to obtain mandamus)
Dikeman v. Snell, 490 S.W.2d 183 (Tex. 1973) (void orders may be challenged by mandamus regardless of appellate remedy)
Mapco, Inc. v. Forrest, 795 S.W.2d 700 (Tex. 1990) (defines when an order is void vs. voidable)
Glunz v. Hernandez, 908 S.W.2d 253 (Tex. App.—San Antonio 1995) (acts contrary to statute are voidable, not necessarily void)
In re Int'l Profit Assocs., Inc., 214 S.W.3d 672 (Tex. 2007) (equitable principles inform mandamus relief)
In re Users Sys. Servs., Inc., 22 S.W.3d 331 (Tex. 2000) (mandamus issuance controlled by equitable considerations)
Rivercenter Assocs. v. Rivera, 858 S.W.2d 366 (Tex. 1993) (mandamus procedural and equitable framework)