in the Interest of J.J.R.S. and L.J.R.S., Children, 627 S.W.3d 211

Law enforcement responded to an aggravated-robbery incident at a motel where Mother and her two children were found; police recovered small amounts of drugs and paraphernalia. Children were placed with maternal Aunt and Uncle and referred to DFPS.
DFPS filed for emergency removal and temporary sole managing conservatorship; a Chapter 262 adversary hearing occurred while Mother had not been served, and the court entered temporary orders under Tex. Fam. Code § 262.201(o).
Mother largely failed to engage with services, refused drug testing, missed most scheduled visits, and did not obtain stable housing or employment during the case. Aunt and Uncle provided stable care; children improved in school and therapy.
At final trial the court named Aunt and Uncle permanent managing conservators and Mother a possessory conservator, but limited Mother’s access to visits "mutually agreed" or, absent agreement, supervised visits at the managing conservators’ "sole discretion" (handwritten).
Mother appealed, challenging (1) authority to vest managing conservators with sole discretion over access and (2) facial and as-applied constitutionality of § 262.201(o) for allowing ex parte temporary orders without prior notice.
The Texas Supreme Court affirmed: it held the nonspecific, severe restriction was permissible where supported by the children’s best interest and deemed the constitutional challenge moot because a final judgment had issued.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (DFPS)	Held
Whether a trial court may vest a managing conservator with sole discretion over a possessory parent’s access (an "as agreed" order)	The order effectively denies Mother access, is impermissibly vague, and exceeds the Family Code’s limits on restrictions	The Family Code permits nonspecific orders when good cause exists and restrictions may be as severe as needed to protect the child’s best interest	Court: Permissible in rare cases. §§153.006(c) and 153.193 allow an "as agreed" restriction where supported by best-interest findings; this record provided legally sufficient evidence for the severe restriction
Whether Tex. Fam. Code § 262.201(o) (allowing ex parte temporary orders when a parent’s location is unknown) is facially or as-applied unconstitutional for depriving notice before a Chapter 262 hearing	§262.201(o) is facially invalid because it permits removal without prior notice to transient parents; its application to Mother violated due process	The statute is permissive and allows ex parte temporary orders only when a parent cannot be located; procedural protections apply at the adversary hearing	Court: Did not reach the merits—constitutional challenge is moot because the trial court later entered a final order that renders the prior temporary order irrelevant to Mother’s current rights

Lenz v. Lenz, 79 S.W.3d 10 (Tex. 2002) (trial court best positioned to resolve fact-intensive conservatorship determinations)
Worford v. Stamper, 801 S.W.2d 108 (Tex. 1990) (abuse-of-discretion standard for family-court rulings)
Ex parte Slavin, 412 S.W.2d 43 (Tex. 1967) (contempt requires a decree to be clear, specific, and unambiguous)
Ex parte Gorena, 595 S.W.2d 841 (Tex. 1979) (enforceability by contempt depends on the nature of the decree)
Heckman v. Williamson County, 369 S.W.3d 137 (Tex. 2012) (mootness: courts lack jurisdiction to issue advisory opinions when final judgments render prior orders irrelevant)
In re H.S., 550 S.W.3d 151 (Tex. 2018) (statutory interpretation starts with the plain meaning of the text)
In re K.A.M.S., 583 S.W.3d 335 (Tex. App.—Houston [14th Dist.] 2019) (upholding an "as agreed" restriction where evidence showed it served the child’s best interest)