Texas Supreme Court
In Re Jane DOE 2
March 7, 20002000 Tex. LEXIS 25
Summary
The Texas Supreme Court vacated the trial court’s denial of a minor’s request for a judicial bypass of parental notification and remanded for a new hearing consistent with its earlier Doe 1 opinion. It held that the best‑interest determination is reviewed for abuse of discretion, that the trial court’s finding of no evidence of potential abuse was unsupported, and that the trial court may not raise constitutional issues sua sponte. The Court also directed specific findings on maturity, best interests, and potential abuse. Justice Hecht’s dissent and Justice Owen’s concurrence are noted at the end of this summary.