in the Interest of A.W., Children, 384 S.W.3d 872

This is an appeal from a trial court order terminating parental rights in Texas.
The Associate Judge signed a handwritten Report and Order on March 21, 2012; notice of appeal was due April 10, 2012.
Appellant filed a notice of appeal on April 26, 2012; a 15-day grace period for extensions applied but expired April 25, 2012.
Appellant’s Anders brief contends the handwritten order was final and that jurisdiction exists; it disputes finality of the May 8, 2012 typewritten order.
The court analyzes whether the March 21, 2012 Associate Judge’s Order was final and appealable and ultimately dismisses for lack of jurisdiction.
The court concludes the handwritten order was final and the appeal was untimely; no out-of-time appeal based on ineffective assistance was preserved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the March 21, 2012 order final and appealable?	Handwritten order disposed of the case as final.	Typewritten May 8, 2012 order should be treated as final.	Handwritten order final; appeal untimely.
Does the absence of 263.405(b)'s explicit statement affect finality?	Lack of statement undermines finality.	Statement absence does not affect finality.	Absence does not affect finality.
If findings required by section 161.001 are missing, does that affect finality?	Missing specific findings undermine finality.	Finality preserved; remand for findings if needed.	Finality preserved; remand not necessary for finality.
Should Pursley v. Ussery (divorce context) control the outcome?	Pursley distinguishes handwritten vs. typed orders on finality.	Parental-termination finality standards apply; Pursley limited.	Pursley distinguished; parental termination finality standards applied.
Is ineffective-assistance-related out-of-time appeal preserved to avoid dismissal?	Ineffective assistance could justify out-of-time appeal.	No preservation of such issue; jurisdiction remains lacking.	Ineffective-assistance challenge not preserved; dismissal maintained.

Pursley v. Ussery, 982 S.W.2d 596 (Tex. App.—San Antonio 1998) (handwritten vs. typewritten orders; finality analysis for judgments)
In re M.H., 745 S.W.2d 424 (Tex. App.—Houston [14th Dist.] 1988) (remand for findings when findings missing; finality unchanged)
In re B.L.D., 113 S.W.3d 340 (Tex. 2003) (preservation of error in parental termination; finality standards)
North East I.S.D. v. Aldridge, 400 S.W.2d 893 (Tex. 1966) (principles relating to finality of judgments)
In re R.B.M., 338 S.W.3d 755 (Tex. App.—Houston [14th Dist.] 2011) (out-of-time appeal and jurisdictional considerations in termination cases)