in the Interest of D.C.C, Children, 2011 Tex. App. LEXIS 9572

Appellant, mother, was incarcerated during termination proceedings for her two children.
Trial proceeded without her appearance; counsel announced not ready due to transfer to a non-county facility.
Mother’s counsel sought participation via video conference but arrangements were not made; court denied motion for new trial.
Texas law recognizes inmate access rights but weighs institutional integrity; factors include transport cost, safety, credibility, and availability of alternative testimony.
Attorney failed to request continuance or provide detailed justification; trial proceeded despite absence.
Court affirmed termination after finding grounds under Texas Family Code §161.001(1)(N)-(P) and (2), and best interests; evidence supported two other predicate grounds, making one sufficient for termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion denying inmate participation.	Appellant (mother) should have been allowed participation or delay.	Court allowed proceeding; record lacked sufficient specificity to justify appearance.	No abuse; record did not show sufficient grounds for appearance.
Whether counsel was ineffective for not objecting to grounds for termination.	Counsel ineffective for failing to challenge ground (0) due to age of child.	Record silent on why objection not raised; other grounds suffice for termination.	No prejudice; two other predicate findings supported termination.

In re Z.L.T., 124 S.W.3d 163 (Tex. 2003) (inmate access rights balanced against court efficiency; bench warrants determine necessity of appearance)
In re M.S., 115 S.W.3d 534 (Tex. 2003) (effective assistance standard for parental termination similar to Strickland)
In re A.V., 113 S.W.3d 355 (Tex. 2003) (one predicate finding can support termination with best interests finding)