in the Interest OF P.Z.F., a Child, 05-21-00161-CV

DFPS obtained an ex parte temporary managing-conservator order for P.Z.F. on May 14, 2018; the automatic dismissal deadline under Tex. Fam. Code § 263.401(a) was May 20, 2019.
The court scheduled trial for April 17, 2019; on May 16, 2019 the docket sheet reflects a continuance and that parties were awaiting an interstate home-study (ICPC) and had a mediated settlement agreement.
The court entered an October 11, 2019 written Order of Monitored Return/Extension stating it would extend jurisdiction and set dismissal for March 23, 2020, and authorized a monitored return of the child to Mother while DFPS remained TMC.
Trial began March 5, 2020 (before the March 23 dismissal date) and the trial court signed a Decree of Termination terminating Father’s parental rights on March 9, 2021.
Father appealed, arguing the Decree was void because the trial court lost jurisdiction by failing to properly extend the automatic dismissal date under § 263.401(b).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the termination decree is void because the trial court lost jurisdiction by failing to validly extend the § 263.401 automatic dismissal date.	DFPS: The May 16, 2019 docket entry constituted a court-ordered extension under § 263.401(b) (as interpreted in In re G.X.H.), the court later issued a written monitored-return order under § 263.403 resetting dismissal to March 23, 2020, and trial began before that date.	Father: The May 16 entry was insufficient—extensions by agreement are prohibited, no motion or required § 263.401(b) findings were filed or written, no new dismissal date was on the docket then, and no reporter’s record exists to show oral findings.	Court affirmed. Applying the Texas Supreme Court’s reasoning in G.X.H., the May 16 docket entry reasonably is read as the court’s extension of the dismissal date; the later monitored-return order under § 263.403 set a March 23, 2020 dismissal and trial commenced before that date, so the decree is not void.

In re D.S., 602 S.W.3d 504 (Tex. 2020) (a judgment is void if the court lacked jurisdiction; appellate courts may decide voidness).
Freedom Commc’ns., Inc. v. Coronado, 372 S.W.3d 621 (Tex. 2012) (appellate courts have authority to determine and remedy void judgments).