in the Interest of I.C.G., a Child, 05-14-01629-CV

Child (I.C.G.) born 2004; Mother and Father were not married. Parents signed an Acknowledgment of Paternity in December 2004.
In 2007 a trial court appointed Mother and Father joint managing conservators and ordered Father to pay child support; various custody/support disputes followed.
In 2013 Child filed (through Mother as next friend) a petition challenging the paternity acknowledgment, alleging another man (E.H.) is the biological father and seeking name change; alternatively sought involuntary termination of Father under Tex. Fam. Code §161.001(1)(D) and (E).
Trial court suspended Father’s possession and child-support obligations, appointed an amicus attorney for the child, and later conducted a bench trial on termination.
Trial court terminated Father’s parental rights under subsection (D); ordered Mother to initiate a suit to adjudicate E.H. as father and permitted birth-certificate name change.
Father appealed arguing lack of standing/subject-matter jurisdiction, insufficiency of evidence, and trial error; Court of Appeals stayed parts of the termination order and addressed jurisdiction first.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had jurisdiction to terminate Father’s parental rights because Child (through Mother as next friend) lacked standing	Child (via Mother) sought termination and asserted the suit was brought by the child through his guardian/next friend	Father argued the amended petition did not plead a statutory basis giving the child standing to seek involuntary termination; standing is required for subject-matter jurisdiction	Court held Child lacked standing as pleaded; trial court lacked subject-matter jurisdiction; termination order vacated and petition dismissed

In re M.K.S.-V., 301 S.W.3d 460 (Tex. App.—Dallas 2009) (standing is a jurisdictional prerequisite; petitioner must allege facts showing jurisdiction)
In re E.G.L., 378 S.W.3d 542 (Tex. App.—Dallas 2012) (party seeking relief in SAPCR must plead and establish standing under Family Code)