Carolyn Jean Brown, Petitioner v. McLennan County Children's Protective Services, Respondent

Summary

The Texas Supreme Court affirmed the trial court’s decree terminating Carolyn Jean Brown’s parental rights, holding that the irrevocable affidavit of relinquishment executed by Brown validly waived service of process and that the statutory provisions allowing such waiver satisfy due‑process requirements. The Court further held that a statement of facts was not required in the record and that Brown was not entitled to appointed counsel in this voluntary relinquishment proceeding. Justice Pope dissented, arguing that pre‑suit waivers of citation violate due process.