in the Interest of K.A.H., a Child, 05-16-01067-CV

DFPS removed three-year-old K.A.H. after an August 2015 referral showing bruising; petition filed August 6, 2015.
Child returned to Mother on a monitored return in February 2016, then re-removed after severe traumatic brain injuries on February 28, 2016; hospitalization, coma, and rehab followed. DFPS filed for termination; dismissal deadline set for August 26, 2016.
Mother’s retained counsel withdrew May 2, 2016; Mother delayed requesting appointed counsel and new counsel was appointed June 2, 2016.
New counsel filed a written answer and jury demand on June 29, 2016 (35 days before the August 3, 2016 trial setting). Discovery deadline was five days later.
On August 3, 2016 the Department moved to proceed as a bench trial to permit mediation and still complete proceedings before the August 26 dismissal deadline; the trial court found the June 29 demand, though filed more than 30 days before the setting, was not made a "reasonable time" before trial under Tex. R. Civ. P. 216 and denied the jury demand.
The court recessed and later conducted a bench trial on August 24, 2016, terminating Mother’s parental rights; Mother appealed only the denial of the jury demand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying Mother’s jury demand	Mother: jury demand filed >30 days before trial satisfied Tex. R. Civ. P. 216; denial was improper	Department/Court: demand, though >30 days, was not filed a "reasonable time" before trial given looming dismissal deadline, docket constraints, and need for expert discovery	Court: No abuse of discretion; denial justified because demand was not timely in a practical sense under Rule 216 and would have disrupted docket and prejudiced parties

Mercedes–Benz Credit Corp. v. Rhyne, 925 S.W.2d 664 (Tex. 1996) (standard for reviewing denial of jury demand and discretionary rulings)
Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238 (Tex. 1985) (abuse-of-discretion standard explained)
Halsell v. Dehoyos, 810 S.W.2d 371 (Tex. 1991) (presumption that a jury demand filed >30 days before trial is reasonable unless it would injure the opposing party or disrupt the docket)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (procedural requirements and standards in parental-rights termination proceedings)
In re J.N.F., 116 S.W.3d 426 (Tex. App.—Houston [14th Dist.] 2003) (appellate review of trial court’s denial of jury demand under abuse-of-discretion)
Gen. Motors Corp. v. Gayle, 951 S.W.2d 469 (Tex. 1997) (constitutional protection of the jury right)