In THE INTEREST OF D.S., a CHILD v. the State of Texas, 602 S.W.3d 504

D.S. was born in Massachusetts; parents married and previously lived in Texas. Mother lived in Collin County, Texas; Father had moved to Massachusetts.
Mother filed for divorce in Collin County and amended to sever Father’s parental rights based on Father’s unrevoked affidavit of voluntary relinquishment. Father was a nonresident.
The trial court held an evidentiary hearing, found it had jurisdiction under Chapter 152 (UCCJEA), and entered an agreed order terminating Father’s parental rights and appointing Mother sole managing conservator.
Months later Father filed a bill of review claiming Texas lacked subject‑matter jurisdiction because Massachusetts was the child’s home state when the termination commenced.
The trial court denied relief; the court of appeals reversed, holding a home‑state error under Chapter 152 could be collaterally attacked despite Tex. Fam. Code § 161.211(c).
The Texas Supreme Court granted review and held § 161.211(c) bars collateral attacks on voluntary‑relinquishment terminations except for fraud, duress, or coercion, reversing the court of appeals and denying Father relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Tex. Fam. Code § 161.211(c) permits a collateral attack on an agreed termination based on an erroneous Chapter 152 (home‑state) jurisdictional finding	Father: § 161.211(c) should not preclude a collateral attack because the trial court lacked jurisdiction—Texas was not the child’s home state	Mother: § 161.211(c) plainly limits collateral attacks to fraud, duress, or coercion; trial court’s Chapter 152 finding is conclusive in collateral attack	Held: § 161.211(c) bars collateral challenges based on erroneous home‑state determinations; petition for relief denied (court of appeals reversed)
Whether extrinsic evidence is admissible to show lack of jurisdiction when the termination record is facially regular and the trial court previously considered jurisdiction	Father: extrinsic evidence proves no home state and jurisdictional defect	Mother: trial court’s jurisdictional findings are conclusive; extrinsic evidence is not permitted in collateral attack	Held: Court did not decide; appeal disposed on § 161.211(c) ground and court declined to reach admissibility issue

In re K.S.L., 538 S.W.3d 107 (Tex. 2017) (§161.211(c) limits post‑judgment attacks on voluntary relinquishment terminations to fraud, duress, or coercion)
Moore v. Brown, 408 S.W.3d 423 (Tex. App.—Austin 2013) (UCCJEA jurisdictional challenge to voluntary relinquishment termination is barred by §161.211(c))
Browning v. Prostok, 165 S.W.3d 336 (Tex. 2005) (finality of judgments; collateral attacks disfavored)
Santosky v. Kramer, 455 U.S. 745 (U.S. 1982) (parental rights are a fundamental interest warranting procedural protections)
Dubai Petroleum Co. v. Kazi, 12 S.W.3d 71 (Tex. 2000) (Texas district courts are courts of general jurisdiction; discussion of subject‑matter jurisdiction concepts)