In re Interest of K.S.L., 538 S.W.3d 107

Infant K.S.L. was removed after both parents tested positive for methamphetamine and had histories of drug use and related criminal incidents, including a high-speed police chase.
The Department of Family and Protective Services became temporary managing conservator and shifted the permanency plan from reunification to relative adoption.
In December 2015 both parents, represented by counsel, signed statutorily compliant affidavits of voluntary, irrevocable relinquishment stating termination was in the child’s best interest.
The trial court admitted the affidavits, heard brief testimony from the caseworker (who supported relinquishment and an uncle’s planned adoption), expressly found by clear and convincing evidence that termination was in the child’s best interest, and entered termination orders.
Parents appealed solely arguing the evidence was legally and factually insufficient to support the trial court’s best-interest finding; they did not allege fraud, duress, or coercion in signing the affidavits.
The Texas Supreme Court reversed the court of appeals and reinstated the trial court’s termination orders, holding the affidavits (and the record) supported the best-interest finding and that statutory limits on appellate attacks comport with due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an unrevoked, statutorily compliant affidavit of relinquishment precludes appellate review of the trial court’s best‑interest finding under Tex. Fam. Code §161.211(c)	Parents: §161.211(c) should be read to permit challenges to the termination order’s best‑interest finding, not just attacks on the affidavit	State/Department: §161.211(c) bars appeals attacking a termination order except on fraud, duress, or coercion in the affidavit; a knowing affidavit can supply clear and convincing evidence of best interest	Held: §161.211(c) limits appeals from termination orders based on relinquishment affidavits to fraud/duress/coercion claims; a valid affidavit can, in the ordinary case, support a clear‑and‑convincing best‑interest finding
Whether limiting appellate review under §161.211(c) violates federal due process	Parents: precluding review of best‑interest sufficiency denies due process and the protections of Santosky	State: statutory safeguards (detailed affidavit requirements and right to appeal on fraud/duress/coercion) plus waiver by a knowing, voluntary affidavit satisfy due process; finality and prompt placement interests are compelling	Held: No due process violation. The statute’s procedural safeguards, waiver principles, and the State’s interest in prompt, final placement satisfy Matthews balancing

Brown v. McLennan County Children's Protective Servs., 627 S.W.2d 390 (Tex. 1982) (holding a voluntary, knowing affidavit of relinquishment may supply evidence that termination is in the child’s best interest)
Santosky v. Kramer, 455 U.S. 745 (U.S. 1982) (establishing clear‑and‑convincing evidence standard for involuntary termination of parental rights)
Lassiter v. Department of Social Services, 452 U.S. 18 (U.S. 1981) (due process analysis in parental‑rights contexts; appointment of counsel not required in every case)
Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (three‑factor balancing test for what process is due)
United States v. Mezzanatto, 513 U.S. 196 (U.S. 1995) (discussing voluntary and knowing waiver of constitutional rights in plea‑type contexts)