in the Interest of J.D. and S.D., Children, 10-16-00105-CV

CPS removed two children after Appellant (mother) admitted she bit her nine-year-old (J.D.) as punishment and exhibited delusions/hallucinations; Appellant was later diagnosed with schizophrenia.
Service plan required psychiatric and psychological evaluations, medication, and proof of mental stability before visitation; Appellant did not provide timely medical documentation showing stability.
Children were placed in a foster home that was a prospective adoptive placement and were reported to be doing well in therapy and no longer reporting voices or demons.
At trial, Appellant belatedly produced a December 11, 2015 MHMR letter indicating medication and improvement, a December lease, and a January SSI letter; CPS considered these last-minute and insufficient given prolonged instability, alleged undisclosed methamphetamine use, homelessness, and employment issues.
Appellant requested a 180-day extension under Tex. Fam. Code § 263.401(b); the trial court denied the extension and terminated parental rights under subsections E and O, finding failure to comply with the service plan and endangering conduct.

Issue	Appellant's Argument	CPS/Respondent's Argument	Held
Whether the trial court abused its discretion by denying a 180-day extension under Tex. Fam. Code § 263.401(b)	Appellant argued that recent progress (MHMR letter, lease, SSI) justified a six-month extension to complete services and demonstrate stability	CPS argued Appellant’s progress was too late, lacked corroborating documentation over time, and that long-term stability (medication adherence, sobriety, housing, self-management) was not shown; six months would be insufficient	Trial court did not abuse discretion; denial affirmed because some evidence supported finding no extraordinary circumstances and that extension was not warranted

In re D.M., 244 S.W.3d 397 (Tex. App.—Waco 2007) (standard of review for extension request under § 263.401(b) is abuse of discretion)
In re A.J.M., 375 S.W.3d 599 (Tex. App.—Fort Worth 2012) (focus on child’s needs and whether extraordinary circumstances justify continued temporary custody)
In re D.W., 249 S.W.3d 625 (Tex. App.—Fort Worth 2008) (abuse-of-discretion analysis: trial court need only have some substantive and probative evidence to support its decision)