In Re Mv, 343 S.W.3d 543

Mother and Father, Indian nationals, married in 2007 and moved to the U.S.; M.V. born May 12, 2008.
Father repeatedly abused Mother during pregnancy and after, including a violent October 2008 incident leading to CPS involvement.
Mother signed an irrevocable affidavit of relinquishment Dec. 22, 2008 and left M.V. with CPS in Collin County; moved to India.
Mother returned to Dallas June 2009, resumed life with Father, and then Father forced her back to India in July 2009 to prevent testimony at his trial.
Department filed for termination of parental rights October 1, 2009; Mother entered a shelter and began counseling about November 2009.
A jury found termination of Mother's rights supported by statutory grounds and in M.V.'s best interests; trial court appointed the Department permanent managing conservator.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of appeal and points	Mother	Department	Moot; court did not address merits
Sufficiency of evidence to terminate	Mother	Department	Sufficient evidence supports grounds and best interest
Venue improper in Collin County	Mother	Department	Not preserved; waived due to lack of written motion
Procedural due process right to counsel for relinquishment	Mother	Department	Not preserved; merits not addressed

In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (clear and convincing standard; review framework)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (nonexclusive Holley factors for best interest)
In re R.R., 209 S.W.3d 112 (Tex. 2006) (best interest consider factors and parental capabilities)
In re M.N., 262 S.W.3d 799 (Tex. 2008) (extension of time to file statements; good cause standard)