In the Interest of J.F.R.R. v. the State of Texas, 04-25-00098-CV

This case involves the termination of Brandon P.'s parental rights over child J.F.R.R.
The trial was set to be conducted in person in Guadalupe County, Texas, with Brandon P. given prior notice.
On the day of trial, Brandon P. was not present and his counsel requested participation by Zoom or telephone, citing Brandon P.'s residence in the Odessa area.
The trial court denied the request, noting no prior objection or request was made, and overruled the counsel's "not ready" announcement.
Brandon P. appealed, arguing the trial court's refusal to allow virtual participation was an abuse of discretion.
The appellate court reviewed the issue under the abuse of discretion standard and affirmed the termination order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether refusal to allow remote participation was abuse of discretion	Brandon P.: Trial court should have allowed virtual appearance due to distance and prior remote hearings.	State: Proper notice was given; request was untimely and lacked good cause.	No abuse of discretion; trial court acted within its authority.

In re M.P.S., 632 S.W.3d 241 (Tex. App.—Eastland 2021) (addresses due process rights of incarcerated parents to participate in trial)
In re L.M.I., 119 S.W.3d 707 (Tex. 2003) (requirement to preserve constitutional due process complaints for appellate review)
In re D.K., 696 S.W.3d 787 (Tex. App.—Eastland 2024) (failure to present constitutional complaint precludes appellate review)