in the Interest of B.C., a Child, 02-16-00431-CV

Grandmother (P.T.) filed an original SAPCR on June 30, 2016 seeking appointment as sole managing conservator of B.C., an ~18‑month‑old child, alleging parents had a history of neglect and that Grandmother had standing under Tex. Fam. Code §102.003(9).
Mother (M.M.) was served July 11, 2016; Father (H.C.) waived service and approved the final order’s form and content but neither parent filed an answer.
The trial court conducted the matter on August 8, 2016, entered a final order the same day, finding Mother in default and waiving a record of testimony.
The court appointed Grandmother sole managing conservator and named Mother and Father possessory conservators.
The order provided Mother “possession of and access to [B.C.] at all times mutually agreed upon in advance by [Mother] and [Grandmother],” and allowed Grandmother to require supervised access if she determined it necessary.
Mother filed a restricted appeal claiming the mutual‑agreement possession language improperly vested Grandmother with unbridled discretion to deny her visitation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by ordering Mother’s possession "at all times mutually agreed upon in advance by [Mother] and [Grandmother]" (i.e., whether that language gives Grandmother unbridled discretion to deny access)	The mutual‑agreement language vests Grandmother with unrestrained discretion to deny Mother visitation and is unenforceable by contempt.	The language is similar to prior approved orders making visitation subject to mutual agreement; if Grandmother obstructs or is unreasonable, Mother can seek court intervention and specific enforceable terms.	The court affirmed: the mutual‑agreement provision is not an abuse of discretion and does not show reversible error on the face of the record.

Halleman v. Halleman, 379 S.W.3d 443 (Tex. App.—Fort Worth 2012) (abuse‑of‑discretion standard applies to possession and visitation determinations)
Watson v. Watson, 286 S.W.3d 519 (Tex. App.—Fort Worth 2009) (elements for restricted appeal; error must be apparent on face of record)
Etheredge v. Hidden Valley Airpark Ass’n, Inc., 169 S.W.3d 378 (Tex. App.—Fort Worth 2005) (restricted appeal requirements should be liberally construed)