Royce Allen Phillips v. Alicia Lucile Phillips, 14-19-00618-CV

Wife filed for divorce in Harris County's 246th District Court in 2018; in March 2019 she separately filed for a protective order in the 280th District Court (the county's designated domestic violence court).
The 280th issued an ex parte temporary protective order; after a multi-day hearing the court signed a final protective order on May 24, 2019 finding family violence by Husband and issuing a 24‑month order.
Husband moved to dismiss/abate, arguing the 280th lacked subject‑matter jurisdiction because the divorce suit was pending in the 246th; the record shows no ruling on that motion and Husband did not seek transfer.
Husband requested findings of fact and conclusions of law under Tex. R. Civ. P. 296/297; the court did not file a separate findings document beyond the findings included in the protective order.
The protective order later expired; the court addressed mootness and applied the collateral‑consequences exception to permit appellate review given stigma and legal effects of a family‑violence finding.

Issue	Husband's Argument	Wife's Argument	Held
Whether the 280th District Court had subject‑matter jurisdiction to hear a protective‑order application filed while a divorce was pending in another district court under Tex. Fam. Code §85.062	§85.062 (and §82.005) made filing in the court where the dissolution suit is pending mandatory/jurisdictional; therefore the 280th was without jurisdiction	Filing elsewhere is permitted by Chapter 85 provisions (notification/transfer); compliance with §85.062 is not jurisdictional and public policy favors immediate protection	Compliance with §85.062 is not jurisdictional; 280th had subject‑matter jurisdiction; Husband’s dominant‑jurisdiction/venue objections were not preserved and he waived transfer
Whether the trial court erred by failing to file separate findings of fact and conclusions of law after Husband’s Rule 296 request	Absence of separate findings prevented meaningful appellate review because the court did not identify which evidence supported the family‑violence finding	The protective order itself contained the statutorily required findings that family violence occurred and is likely to occur; the court was not required to catalogue every evidentiary detail	No reversible error; the findings in the final protective order satisfied statutory requirements and Rule 296 did not require a separate, detailed findings document in this context

Heckman v. Williamson Cnty., 369 S.W.3d 137 (Tex. 2012) (mootness and subject‑matter jurisdiction principles)
Marshall v. Housing Auth. of the City of San Antonio, 198 S.W.3d 782 (Tex. 2006) (collateral‑consequences exception to mootness)
State for Prot. of Cockerham v. Cockerham, 218 S.W.3d 298 (Tex. App.—Texarkana 2007) (protective‑order stigma and reviewability)
In re Salgado, 53 S.W.3d 752 (Tex. App.—El Paso 2001) (policy favoring immediate access to protective orders)
Ulmer v. Ulmer, 130 S.W.3d 294 (Tex. App.—Houston [14th Dist.] 2004) (protective order can be final and appealable)
Helena Chem. Co. v. Wilkins, 47 S.W.3d 486 (Tex. 2001) (statutory "must" as condition precedent; mandatory language not automatically jurisdictional)
Albertson's, Inc. v. Sinclair, 984 S.W.2d 958 (Tex. 1999) (when statute silent on consequences of noncompliance, courts consider statute’s purpose to determine remedy)