CHAPTER TWENTY-TWO - Special Immigrant Juvenile Status ...

22-1 Updated October 2016

CHAPTER TWENTY-TWO

Special Immigrant Juvenile Status

(Family Law Portion)

A certain class of particularly vulnerable immigrant children is entitled to special protections under U.S. law. Regardless of the manner in which they arrived to the U.S., Special Immigrant Juvenile Status allows a child to remain in a safe environment in the U.S., to attend school, and eventually to obtain lawful permanent residency. Many of the unaccompanied children and teens arriving in the U.S. are often orphans, neglected, or fleeing abusive home lives, they are defenseless and often targets of exploitation—both in their home countries and in the U.S.

ro bono1 assistance is critical to protect an unaccompanied child’s rights because without legal counsel these children may never know or exercise their rights.

22.1 Overview

Special Immigrant Juvenile Status (“SIJS”) was specifically created for an undocumented child who is under the jurisdiction of a state juvenile court; who cannot be reunified with the child’s parent(s) due to abuse, neglect, or abandonment; and for whom it would not be in their best interest to return to their home country. Once a child who has received Special Immigrant Juvenile Status becomes a permanent resident, the child’s parents are permanently barred from receiving any immigration benefit based on their relationship to the child.

This chapter provides a substantive overview of the SIJS process, including an in-depth analysis of state court procedures and pleadings.

Sample documents and templates for the family court portion of the SIJS process have been provided in the appendices at the end of this chapter.

22.2 Requirements for Special Juvenile Immigrant Status

The requirements for Special Immigrant Juvenile Status are set out in federal statute2 and regulations.3 A. “Juvenile Court” is to Make Findings as Presented in a Court Order. Federal

regulation provides that any court in the United States with authority to make placement and custody decisions over a juvenile is a “juvenile court” enabled to

1 As with adults placed in removal proceedings, an unaccompanied child “shall have the privilege of being represented, at no expense to the Government.” INA § 240(b)(4) (emphasis added). 2 “Special immigrant juvenile” is defined in the Immigration and Nationality Act (“INA”) § 101(a)(27)(J), codified at 8 USC § 1101(a)(27)(J). The law was created by § 153 of the Immigration Act of 1990. In 2008 the Trafficking Victims Protection Reauthorization Act (TVPRA) modified the requirements for SIJS. The updated INA language is pending. 3 The Code of Federal Regulations sets forth the standards for implementing the statute at 8 CFR § 204.11.

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make SIJS findings.4 Congress purposely designated state courts to make the required predicate findings because these courts hold expertise regarding child-related matters and are best suited to make decisions in the best interest of a child.

The required findings are to be set out in a simple order, signed by the state court judge. The order should include brief but specific findings of fact to show that the court has made an informed decision, and a brief summary of the evidence relied upon to make the findings.5

B. Court Must Declare Child to Be a Court Dependent. A “juvenile court’s”

acceptance of jurisdiction over the custody of a child renders the child dependent on the court for SIJS purposes because such jurisdiction empowers the court to make decisions about the child’s “custody and care.”6 Furthermore, placement of a child in a conservatorship by a court does not preclude a finding of the child’s dependence on the court for SIJS purposes.7

C. Court Must Find that “reunification with 1 or both of the immigrant’s parents is

not viable due to abuse, neglect, abandonment, or a similar basis found under State law”. To establish and maintain eligibility for Special Immigration Status, the statute requires a determination by a state court that “reunification with 1 or both of the immigrant’s parents is not viable due to abuse, neglect, abandonment, or a similar basis found under State law”. 8

1. “Not Viable due to Abuse, Neglect, Abandonment, or a Similar Basis.” The

William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (“TVPRA”) changed the language of 8 U.S.C. Sec. 1101(a)(27)(J) to define a Special Immigrant Juvenile as a juvenile “who has been declared dependent on a juvenile court located in the United States . . . and whose reunification with 1 or both of the immigrant’s parents is not viable due to abuse, neglect, abandonment, or a similar basis found under state law.” Regulations are pending for this new language. The government recognized that the revised language expanded the category of juveniles eligible for Special Immigrant Juvenile status by acknowledging that the new standard is now viability of family reunification instead of eligibility for long term foster care. The Memo states, “In short, the TVPRA 2008 removed the need for a juvenile court to deem a juvenile eligible for long-term

4 Id. § 204.11(a) (defining a “juvenile court” as a court “located in the United States having jurisdiction under State law to make judicial determinations about the custody and care of juveniles.”) 5 “Memorandum #3 – Field Guidance on Special Immigrant Juvenile Status Petitions”, issued by William R. Yates, Associate Director for Operations (May 27, 2004). 6 Id. See also Tex. Fam. Code §§ 152.201, et seq. 7 The issue of a child placed in a conservatorship was conclusively settled in Matter of Menjivar. In that case, which concerned an SIJS case in Dallas, the Administrative Appeals Unit of the then-Immigration and Naturalization Service ruled that the family court’s placement of the child in a conservatorship did not preclude a finding that the child was dependent upon the court for SIJS purposes. Matter of Menjivar, File A070-117-167, INS Administrative Appeals Unit (Dec. 27, 1994). 8 8 USC § 1101(a)(27)(J)(i).


foster care and replaced it with a requirement that the juvenile court find reunification with one or both parents not viable.”9

2. Dependency declarations can take many forms. The majority of HRI’s

dependency declarations10 are typically established through a “Suit Affecting the Parent-Child Relationship”11 (SAPCR) (i.e., managing conservatorship), only a natural parent or a person with a court-ordered obligation or relationship to the child (with few exceptions) is entitled to notice of the suit.12 There is no requirement that other family members be notified of or participate in the suit.13

Therefore, the typical dependency declaration concerns only the parent-child relationship and the state court may find that “family reunification is no longer a viable option” and issue an order that addresses and impacts only the child’s parents.

D. Court’s Findings and Order Must Be Based on Abuse, Neglect, or

Abandonment, or a similar basis of the Child. To be sufficient for SIJS

purposes,14 and to combat claims of fraudulently seeking immigration status, the court’s order should specifically identify abuse, neglect, or abandonment as the basis for the dependency or placement order.

Texas law is specific in what constitutes abuse,15 neglect,16 and abandonment.

E. Court Must Find that Return to Home Country is Not in Child’s Best Interest. In

issuing any order, the paramount concern of the court remains the best interest of the child.17 In concert with public policy of the State, the court’s overarching concern for the child remains provision of a “safe, stable, and nonviolent environment for the child.”18 Thus, where evidence indicates a return to the child’s country of origin would

9 Neufield Memorandum issued March 24, 2009, found at https://www.uscis.gov/sites/default/files/USCIS/Laws/Memoranda/Static_Files_Memoranda/2009/TVPRA_SIJ.pdf.

10 See Tex. Fam. Code § 153, Subchapters B: Parent Appointed as Conservator: In General, and G: Appointment of Nonparent as Conservator. 11 Tex. Fam. Code § 101.032. 12 Tex. Fam. Code § 102.009(a). 13 For this reason, it is imperative that the order state that all parties entitled to notice were properly served. 14 There is no requirement in the statute, regulation, or U.S. Citizenship and Immigration Services memoranda for the abuse, neglect, or abandonment to occur or to have occurred in the United States. Many immigrant children have lost or escaped abusive parents in their country of origin and arrived alone in the United States. The only legal issue is whether the family court has made its determination based on abuse, neglect, or abandonment of the child as defined under state law. 15 Tex. Fam. Code § 261.001(1). 16 Id. § 261.001(4). See Zheng v. Pogash, 416 F. Supp. 2d 550, 559-560 (2006) (discussing “neglect” under Texas law in the context of SIJS). 17 Id. § 153.002 (“The best interest of the child shall always be the primary consideration of the court in determining the issues of conservatorship […].”) 18 Id. § 153.001.


jeopardize the child’s safety or wellbeing, the court should find the child’s return is not in the child’s best interest, and the court’s order should include a finding to that extent.19

The regulations specifically address the state court’s capacity to issue an order declaring a return to the child’s home country not to be in the child’s best interest.20

In issuing field guidance regarding SIJS, the U.S. Citizenship and Immigration Services specifically noted that a decision concerning the best interest of the child “may be made by the [state] juvenile court,” 21 and encourages state courts to “address this issue and incorporate a finding of fact into the court order.”22

A court may find such proof in documentary evidence, or in its own knowledge that the child has no known appropriate or accountable family in the home country to care for the child.

F. State Court Procedures

The two-part process for obtaining SIJS begins in the state court. In the majority of HRI’s cases this is usually commenced by initiating a “Suit Affecting the Parent-Child Relationship” (hereinafter “SAPCR”),23 which seeks the appointment of an individual, including someone other than a child’s parent, to be responsible for the care, custody, and control of the child.

Although public policy considers the rights of parents, of equal concern is the provision of a “safe, stable, and nonviolent environment for the child,”24 which may necessitate appointment of a non-parent managing conservator to care for the child.

19 8 USC § 1101(a)(27)(J)(ii) (defining a special immigrant juvenile as a child “for whom it has been determined in administrative or judicial proceedings that it would not be in the alien’s best interest to be returned to the alien’s or the parent’s previous country of nationality or country of last habitual residence …”). 20 Id. 21 See supra note 5. 22 Id. 23 Tex. Fam. Code § 101.032(a). See generally William V. Dorsaneo, III, Texas Litigation Guide, Chapter 370: SAPCR Procedures (2006).

24 Tex. Fam. Code § 153.001(2).


Family Law Portion of SIJS

Pro Bono (PB) Completes Initial Screening and Establishes Timeline (Child Must Meet 6 Month Residency Requirement)

↓

PB Files SAPCR (and Other Required Documents)

↓

PB Sends Waiver of Service to Parent(s)

or

PB Obtains Service on Parent(s)

↓

PB Files Brief In Support Of The Petition And Motion For SIJS Findings

↓

PB, Client, and Guardian Attend Prove Up Hearing and Receive Order

↓

PB Contacts HRI to Discuss Immigration Portion

A. Definitions. Statutory definitions are of critical importance in establishing the scope

and applicability of SAPCR proceedings, and the rights and duties of the parties.

Comprehension of and familiarity with the following statutory definitions is recommended for a clear understanding of SAPCR proceedings.

“Abandoned” ………………………………………… Tex. Fam. Code § 152.102(1) “Abuse” ………………………………………….…… Tex. Fam. Code § 261.001(1) “Adult” ………………………………………...……… Tex. Fam. Code § 101.003(c) “Best Interest of Child” …………………………...... Tex. Fam. Code § 153.002 “Child” (or “Minor”) ..………………………………… Tex. Fam. Code § 101.003(a) “Danger to Physical Health or Safety of Child” ….. Tex. Fam. Code § 101.009 “Factors in Determining Best Interest of Child” ..... Tex. Fam. Code § 263.307 “Health Insurance” …………………..……………… Tex. Fam. Code § 101.015 “Managing Conservatorship” ………………...….… Tex. Fam. Code § 101.019 “Medical Support” ………………………………..... Tex. Fam. Code § 101.020 “Medical Support Order” …………………………… Tex. Fam. Code § 154.181 “Neglect” ……………………………………......…… Tex. Fam. Code § 261.001(4) “Parent” ……………………………………………… Tex. Fam. Code § 101.024 “Parent-Child Relationship” …...………………...… Tex. Fam. Code § 101.025 “Rights and Duties of Nonparent Appointed as: Sole Managing Conservator” ……………….…. Tex. Fam. Code § 153.371 Joint Managing Conservator” …………….……. Tex. Fam. Code § 153.372 “Suit Affecting the Parent-Child Relationship” ....... Tex. Fam. Code § 101.032


B. Standing. For SIJS purposes, a SAPCR suit may be brought by any of the following

persons:

A child’s parent;

A child’s grandparent;

A child’s relative;

A licensed child placing agency; or

A non-parent adult, provided certain statutory requirements are met.

Although, statutorily, other parties25 may initiate SAPCR proceedings, many of these enumerated parties are unlikely candidates within the SIJS context. The suit may be brought at any time,26 provided the party has satisfied the required time period, if any, for standing to vest. The time need not be continuous and uninterrupted, although the court must give weight to the child’s principal residence27 in the time prior to filing suit in assessing whether the party may properly exercise standing.28

1. The Child. A child can always institute a suit on his or her own behalf with the

involvement of an authorized representative29.

2. A Parent. A child’s parent may file an original suit at any time.30 2. Grandparents. A child’s grandparent my initiate a SAPCR proceeding if (a)

the grandparent has standing as enumerated in the general SAPCR standing statute,31 and (b) there is adequate proof32 that granting managing conservatorship to the grandparent is essential because of a substantial threat of impairment to the child’s “physical health or emotional development.”33

3. Relatives. A child’s relative may file suit if the child’s parents are deceased.34

25 See Tex. Fam. Code § 102.003(1) – (8), (10), (14). 26 Tex. Fam. Code § 102.001(a). 27 Doncer v. Dickerson, 81 S.W.3d 349, 358-362 (Tex. App.–El Paso 2002) (defining “principal residence” as (1) a fixed place of abode, (2) occupied consistently over a substantial period of time, (3) that is permanent rather than temporary.). 28 Tex. Fam. Code § 102.003(b) (applicable to § 102.003(a)(9), (11), (12) only).

29 Tex. Fam. Code § 102.003(a)(2).

30 Tex. Fam. Code § 102.003(1).

31 Tex. Fam. Code § 102.004(a).

32 Von Behren v. Von Behren, 800 S.W.2d 919, 921 (Tex. App.–San Antonio 1990) (establishing “satisfactory proof” by preponderance of evidence). 33 Tex. Fam. Code § 102.004(a)(1). The grandparent may also establish standing if both parents, the sole surviving parent, or a managing conservator either filed or consented to the suit. Tex. Fam. Code § 102.004(a)(2). 34 Tex. Fam. Code § 102.003(a)(13) (limiting exercise of standing to child’s relatives within third degree by consanguinity).


Only the following relatives,35 however, may initiate SAPCR proceedings:

Parent;

Sibling;

Grandparent;

Great-grandparent;

Aunt or uncle; or

Niece or nephew.

4. Non-Parent with Actual Possession and Control of the Child. With the exception of a foster parent, any person who has exercised “actual possession and control” of the child for a minimum of six months – and at least within 90 days of filing suit – may initiate SAPCR proceedings.36

Likewise, a person who lived in the same household37 as the child and the child’s parent or managing conservator may file suit if that parent or managing conservator is deceased when the suit is filed.38 As above, the period of joint residence required is a minimum of six months and at least within 90 days of filing suit.

C. Venue. Generally, SAPCR proceedings must be initiated in the county where the

child resides.39

Numerous exceptions exist.40 In the context of SIJS, an exception to the general venue rule is commonly the county of the non-parent adult with “actual care, control, and possession” of the child.41

D. Requisites of Suit

1. SAPCR. A SAPCR suit is commenced by the filing of a petition.42 Subsequent

pleadings (e.g., motions, memoranda) are to be specifically styled43 and filed under the same docket number, as issued by the clerk of the court, without additional letters, digits, or special designations.

35 Tex. Gov. Code § 573.023(c) (delineating relatives within third degree by consanguinity). See also Tex. Gov. Code § 573.021, et seq. 36 Tex. Fam. Code § 102.003(a)(9). 37 Tx. Dept. of Prot. and Reg. Ser. v. Sherry, 46 S.W.3d 857, 861 (Tex. 2001). 38 Tex. Fam. Code § 102.003(a)(11). 39 Tex. Fam. Code § 103.001(a).

40 See Tex. Fam. Code § 103.001(a) (venue fixed by court exercising continuing exclusive jurisdiction or by suit for dissolution of marriage). See id. § 103.001(b) (venue for adoption), § 103.001(c) (cataloging exceptions). 41 Id. § 103.001(c).

42 Tex. Fam. Code § 102.002. 43 Tex. Fam. Code § 102.008(a).


A petition in a SAPCR proceeding must include each of the following items:44

Statement that no court has continuing jurisdiction;45

Child's name, date of birth, and county of residence;46

Full name, county of residence,47 and description of petitioner’s relationship to the child (or allegation that no relationship exists);

Names of child’s parents;48

Description and statement of value of all property owned or possessed by the child;

Statement describing the action the court is requested to take concerning the child and the statutory grounds for the request; and

Any other information required by statute.

Include the residence addresses of all persons entitled to service of citation:

In the petition itself;49 or

In the Waiver of Service; or

In a cover letter to the process server.

2. Other Required Documents. In addition to filing the original SAPCR suit, the

following supporting and administrative documents are required:

“Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) Affidavit”

Citation of Service Affidavit(s) o “Waiver of Service” (if parent’s location is known); or o “Affidavit for Citation by Publication” (if parent is missing and unable to

be located)

“Health Insurance Availability Form”

“Information on Suit Affecting the Family Relationship” (i.e., often times referred to as the “Austin” form). The form is available online at: http://www.dallascounty.org/districtclerk/downloadableforms.html

44 Tex. Fam. Code § 102.008(b). 45 Or a statement that the court in which the petition is filed has continuing jurisdiction. Tex. Fam. Code § 102.008(b)(1). 46 For both privacy and safety reasons, the Family Code no longer requires that a SAPCR petition state the “place of residence” (i.e., address) of a child or petitioner. The petition should, however, allege the county of residence of both the child and the petitioner to prove proper venue. See also Tex. R. Civ. P. 79 (requiring a petition state the names of the parties and “their residences, if known.”). 47 Id. 48 Tex. Fam. Code § 102.008(b)(4). Although unlikely in the SIJS context, also include names of any court-ordered managing conservator or custodian of the child, guardians of the child's person and estate, possessory conservators or of other persons having access to the child under a court order, and alleged father of the child, or a statement that the identity of the father is unknown. Tex. Fam. Code § 102.008(b)(5)-(8). 49 Tex. Fam. Code § 102.009 (“Service of Citation”).

Practice Tip

Family Court Pleadings should be drafted using the following format: 1.5” top margin 1” side and bottom

margins Times New Roman,

12 pt. font Double-spaced


“Civil Case Information Sheet”

“Citation Publication Request Form” (optional, depending on jurisdiction)

Your initial packet of case information will contain samples of the required items listed above that are required for your case.

E. Order of SAPCR Package:

1. Original Petition in a Suit Affecting the Parent-Child Relationship 2. Child’s Birth Certificate with certified translation 3. Affidavit of Petitioner or Child detailing the grounds for requested finding 4. UCCJEA Affidavit 5. Health Insurance Availability Form 6. Civil Case Information Sheet

F. Requisites of Order

1. State law requirements. The order should be styled “Order in Suit Affecting

the Parent-Child Relationship,” and should include the general nature of the proceedings, including:

Appearances by parties and counsel;

Statement of court’s jurisdiction;

Statement that case was tried by court;

Statement that proceedings were recorded by court reporter; and

Identification of child.50

For each party, including the child (when applicable),51 the court’s final order must contain:

Social security number;52

Driver's license number; 53

Current residence address;54

Mailing address;55

Home telephone number;56

Name of employer;57

50 Including child’s name, sex, date of birth, and home state. 51 It is axiomatic that this information is not required if the child has not yet been issued a social security number or driver’s license number, or is not employed. 52 Tex. Fam. Code § 105.006(a)(1). 53 Id. 54 Id. § 105.006(a)(2).

55 Id. 56 Id.

57 Id.


Address of employment;58 and

Work telephone number.59

The court’s order must also include (in plain type) a notice to advise each other party of a duty to inform each other party of changes to this required information.60 Under certain circumstances,61 the court may order that this information not be disclosed. Additionally, the court’s order must also include the following statutory warnings and notices, which must be prominently displayed in boldface type, capital letters, or underlined:62

Consequences of failure to obey a court order for child support and possession of or access to the child;63

Required notification concerning changes of contact and employment information;64

Authorization of peace officers to use reasonable efforts to enforce child custody order.65

Although these statutory warnings and notices are largely inapplicable in the context of SIJS, each are nonetheless required and must be included.

2. SIJS requirements. To be sufficient for SIJS purposes, the court’s order must

contain the following findings:

The court has jurisdiction under Texas law to make judicial determinations about the custody and care of minors;66

The child is a juvenile;

The child is unmarried;

“dependent” on the court;67

58 Id. 59 Id. 60 Id. § 105.006(b). See also id. § 105.007. 61 Id. § 105.006(c) (Information may be withheld if “likely to cause the child or a conservator harassment, abuse, serious harm, or injury”). 62 Id. § 105.006(d), (e), and (e-1). 63 Id. § 105.006(d). 64 Id. § 105.006(e). 65 Id. § 105.006(e1). 66 8 CFR § 204.11(a). 67 Id.


Reunification with 1 or both parents is not viable due to abuse, neglect, abandonment, or a similar basis under state law;68 and

It is not in the best interests of the child to return to the child’s county of origin or last habitual residence.69

3. Court’s Orders. The court’s order will contain specific orders concerning

conservatorship, including:

Specific findings in support of application for SIJS (as delineated above);

Appointment of petitioner as Managing Conservator;70

Statutory list of exclusive rights and duties of a conservator;71

Limitation of conservator as sole person authorized to apply for and keep child’s passport;

Statement of why parent(s) cannot or should not be appointed as conservators; and

Statement of conservator’s responsibilities concerning child support and healthcare.72

The court’s order will also contain general orders, including:

Notice to each party to pay their own costs;

Discharge of duty to retain discovery materials; and

Notice of denial of all other relief not expressly granted.

Your initial packet of case information will contain a sample of the Order for your case.

F. Service of Citation. All parties entitled to service of citation must be served when a

SAPCR suit is filed.73 To be sufficient in form, a citation must comply with specific statutory requirements.74

1. Waiver of Service. This is the preferable alternative in the SIJS context. The

parent(s) may waive issuance and service of citation.75 This is accomplished by delivering a copy of the filed petition, and a Waiver of Service affidavit to the

68 8 USC § 1101(a)(27)(J)(i). 69 8 USC § 1101(a)(27)(J)(ii).

70 A solitary petitioner will be named as Nonparent Sole Managing Conservator, whereas a pair of petitioners will be named as Nonparent Joint Managing Conservators. There is no requirement that Nonparent Joint Managing Conservators be married. See Tex. Fam. Code § 153.372 (specifically enabling a “nonparent” to serve jointly with another “nonparent”). By the language of the statute, however, no more than two persons may serve jointly. 71 Tex. Fam. Code § 153.371 (‘Rights and Duties of Nonparent Appointed as Sole Managing Conservator”); see also id. § 153.372 (“Nonparent Appointed as Joint Managing Conservator”). 72 See generally Tex. Fam. Code Ch. 54; id. §§ 154.008 (“Provision of Medical Support”), 154.181 (“Medical Support Order”). 73 Tex. Fam. Code § 102.009. 74 See Tex. R. Civ. P. 99(b)-(c). See also Tex. Fam. Code § 102.010(c) (providing template for citation). 75 Tex. R. Civ. P. 119.


respondent(s). The respondent(s) must complete the affidavit, and return the notarized original to the petitioner’s attorney.

When a duly executed waiver is filed with the trial court, it has the same force and effect as if the citation had been issued and served on the party signing the waiver.76

2. Personal Service of Citation. Personal service may be accomplished by one

of two methods:

By personally delivering a copy of the citation with the delivery date endorsed on it, and a copy of the petition; 77 or

By sending a copy of the citation and petition by registered or certified mail, return receipt requested.78

3. Service of Citation by Publication. By the very nature of SIJS, the child’s

parents are the most likely object of service,79 and if presumed to be to be living in another country or their whereabouts are unknown, will be accomplished by service of citation by publication.80

Citation may be served by publication in three circumstances:81

The party’s residence is unknown;

The party is a transient person;

The party is absent from or a nonresident of the state.

Two prerequisites82 must be satisfied before seeking service by publication:

“Due diligence” must have been exercised to locate the party; and

An affidavit reflecting such “due diligence” is filed with the court clerk.

See Appendices for Affidavit for Citation by Publication (Rule 109 Affidavit).

Many, if not most, such citations are published in a particular publication in each county. A notarized copy of the notice will be mailed to the attorney of record; the original citation, with return of service, will be returned to the court and included in the court’s file. It is recommended, however, to frequently check the website after filing to check for timely publication. SAPCR notices are

76 Tex. R. Civ. P. 119. 77 Tex. R. Civ. P. 106(a)(1). 78 Id. 106(a)(2).

79 Id. § 102.009(7). 80 Id. § 102.010 (“Service of Citation by Publication”). 81 Tex. R. Civ. P. 109. 82 Id.


found under “Notices”, in the subheading “Miscellaneous Notices.” Date of publication of the notice may also be obtained by phone.

4. Service of Citation by Posting at the Courthouse. If the child’s parents are

both deceased, however, a request may be made to the court for no personal service. The court will require definitive proof of the parents’ death (e.g., death certificate, affidavits of witnesses to funeral and/or burial service).

If only the child’s mother is deceased,83 and the father is presumed to be living (or cannot be proven to have died), and the father’s last name is unknown, the court may order citation by posting the citation at the courthouse door if this notice “is as likely” to give the respondent “actual notice” of the suit.84 The logic of this exception to citation by publication is that, for an unknown or missing parent located in another country, posting the notice at the courthouse is equally likely to give the respondent actual notice – i.e., slim in either instance. The advantage to citation by posting is cost as there is no need to pay for publication of the notice in the Daily Commercial Record or other publication.

G. Filing an Amended Suit

An amended petition must be complete, both in content and legal sufficiency, because once filed, it will become the “live” pleading for the matter and the original petition is rendered a nullity,85 and will not be a part of the record. Accordingly, the new petition must be appropriately styled (e.g., “Petitioner’s First Amended Petition in Suit Affecting the Parent-Child Relationship”). Generally, new service of citation is not required.86

In the context of SIJS, an amended petition may be filed to correct factual errors or, more commonly, to incorporate additional evidence (e.g., to include additional affidavits from family members or the child to further substantiate the necessity for substituted service by publication, or to provide additional proof of abuse, neglect, or abandonment of the child.).

Once amended, as needed, the only substantive textual alterations occur in the first and last paragraphs, as follows:

“TO SAID HONORABLE COURT: Now comes [Petitioner’s Name], Petitioner, and files this First Amended Original Petition and Suit Affecting the Parent-Child Relationship, incorporating all exhibits and attachments of the Original Petition as if set forth in full herein, and in support hereof would show the Court as follows:

83 The Family Code allows for posting when the last name of any respondent is unknown. As a practical matter, however, in most instances the child’s mother’s name will be known, and accordingly, the above-described scenario is based upon this premise. 84 Tex. Fam. Code § 102.010(e).

85 Tex. R. Civ. P. 65 (“Substituted Instrument Takes Place of Original”). 86 See Sanchez v. Texas Indus., Inc., 485 S.W.2d 385, 387 (Civ. App.–Waco 1972, ref. n.r.e.) (requiring new service of citation only if respondent has not yet appeared and new pleading states a new cause of action or a more onerous judgment).


[…]WHEREFORE, Petitioner asks Respondent take notice of this amended petition and that the Court grant Petitioner the relief sought herein.”

In practice, a petitioner may file an amended petition any time before trial and without filing a formal motion for leave to amend.87 The amended petition may be mailed to the court clerk,88 with a copy89 to be returned by a self-addressed, postage-paid envelope.

H. Waiting Period After Service of Citation. The respondent(s) must file an answer

by 10:00am on the next Monday after 20 days from the date of citation of service.90

Although the date of citation is not counted in computing the 20-day period, all subsequent days are counted, including weekends and holidays.91 If the last day falls on a weekend (i.e., Saturday or Sunday), the last day is moved to the following Monday (subject to the next exception).92 If the last day falls on a holiday, the last day is moved to the next day following the holiday.93

After computing the expiration of 20 days, the respondent must file an answer by the next following Monday.94 If the 20th day falls on a Monday, the respondent has until the following Monday to answer.95

Check with the court clerk prior to scheduling an appointment with the client to attend a prove-up hearing to ensure that citation has been issued and that the return has been filed with the court.

I. Brief in Support of Petition and Motion for SIJS Findings. A “Brief in Support of

Petition and Motion for SIJS Findings” is a reference tool for the court which provides a concise statement of the facts, arguments of the law (with supporting statutes, cases, and other references), and substantive and procedural considerations that will be required to adjudicate a case.

87 Although Rule 63 indicates that leave of court is required for an amended petition filed within seven (7) days before the trial date, as a practical matter, the court will generally allow the filing unless there is a showing by the opposing party that the amended petition will operate as a surprise to the opposing party. Tex. R. Civ. P. 63 (“Amendments and Responsive Pleadings”). 88 Tex. R. Civ. P. 74. 89 As a practical consideration, the copy should be marked as such on each page, not hole-punched, and paper clipped to the self-addressed, postage-paid envelope. If properly done, the court clerk will understand your intentions and return the file-stamped copy to you. 90 Tex. R. Civ. P. 99 (“Issuance and Form of Citation”).

91 Tex. R. Civ. P. 4 (“Computation of Time”). 92 Id. 93 Id. 94 Id. 95 Id.


Though not required by any rule or standing order, submission of a brief in SIJS cases is strongly recommended, largely because it serves a dual purpose as legal resource and persuasive device. Although Human Rights Initiative has undertaken measures to educate the family and juvenile courts about the substantive law and practical considerations governing SIJS, do not overlook an opportunity to provide the judge with a valuable resource tool in the event the judge or associate judge is unfamiliar with this area of law. A sample brief will be provided to you with your initial case packet if it is required in your case. The brief will be submitted after the original SAPCR suit is filed, and may be submitted concurrent with the proposed order. As a pragmatic consideration, not all courts allow the submission of a brief. Please call the court to confirm that the judge will accept the filing before drafting the brief.

J. Appointment of Attorney Ad Litem. An attorney ad litem96 is an attorney who is

appointed by the court to provide legal services to a person, usually the “missing” parent in the SIJS context, and must adhere to the same professional standards and competency as with any other client.97

1. Request for Waiver of Appointment. Although appointment of an attorney ad

litem is discretionary,98 and may only be made if the court determines that an appointment is “necessary to determine the best interests of the child,”99 it is unlikely that the Court will allow for such a waiver. Therefore, we do not advise filing a waiver.

2. Appointment After Publication. If a waiver of appointment has not been

sought or has been denied, a request may be made to the court for an appointment of an attorney ad litem.

The request for appointment should only be made after the return of citation by publication has been filed with the court, and should indicate that the respondent had been cited by publication, after which no answer had been filed and no appearance has been entered by the party within the prescribed time. While there is no specific statutorily prescribed training required of an attorney to be appointed to represent a party as an attorney ad litem,100 the request for

96 Tex. Fam. Code § 107.001(2). 97 Tex. Fam. Code § 107.001(2) (prescribing the duties of “undivided loyalty, confidentiality, and competent representation”).

98 Tex. Fam. Code § 107.021 (“Discretionary Appointments”). 99 Tex. Fam. Code § 107.021(b)(2). 100 But cf. Tex. Fam. Code § 107.003(2) (requiring an attorney ad litem for child to be “trained in child advocacy or have experience determined by the court to be equivalent to that training”).


an appointment should be accompanied by a report from the State Bar101 indicating the following information:

Full Name

Work Address

Work Telephone Number

Bar Card Number

Date Licensed

Eligibility to Practice in Texas

Education and Certification History

Public Disciplinary History (if any) See Appendices for a Sample Appointment of Attorney Ad Litem After

Publication. At the prove-up hearing, the attorney ad litem will submit a Statement of Evidence, which should describe, in detail, the attempts made to locate and identify the respondent, and include any exhibits introduced, made part of the record, and filed with the court. The court may also receive the report orally.

See Appendices for a Sample Attorney Ad Litem Statement of Evidence.

K. Prove-Up Hearing. A prove-up hearing is a brief court appearance before the judge

by the petitioner. If the respondent signs a waiver of service or fails to answer, a prove-up hearing may be held immediately after the required time period has elapsed, subject to local court rules on when prove-up hearings are conducted. Days and times of prove-up hearings vary by court so checking local rules is imperative before scheduling an appointment with the client. Have at least four paper copies of your order with you for the prove-up. Each copy should contain both your signature, and the petitioner’s signature. On the morning of the prove-up hearing,102 check in with the bailiff or court coordinator in the courtroom. You may be asked to provide the court a copy of your proposed order. All matters are handled on a first-come, first-served basis. Each petitioner and counsel should remain in the courtroom until the case is called. Generally, children are not allowed in the courtroom, so unless the judge wishes to ask specific questions of the child, there is no need for the child to attend the prove-up hearing (especially if the child is attending school). After being sworn in by the court, the attorney will ask the petitioner a series of questions to elicit information about the petitioner, their residence, their employment, their knowledge (if any) of the child’s parents and/or their whereabouts, their relationship with the child, and their knowledge of other relevant circumstances

101 For a complete report, visit the State Bar of Texas website at www.texasbar.com and perform an attorney search. The resulting report should provide all of the necessary information, including a statement as to whether the attorney is currently in good standing and eligible to practice law in Texas. 102 Generally, prove-up hearings are conducted in the morning and continue until the first contested matter


concerning the child (e.g., school attendance, social activities and interests). Advise each petitioner that the judge may also ask questions or seek additional clarification. If an Attorney Ad Litem has been appointed by the court, the judge will then receive evidence from the appointee. See Appendices for a Sample Prove-Up Preparation Questionnaire and Prove-Up

Script. Due to the abbreviated nature of a prove-up hearing, it is highly unlikely that the judge will require, expect, or even permit, a brief opening statement. However, in the event that an opening statement is requested or permitted, a concise statement should be provided for the record. At the conclusion of the prove-up hearing, if the judge is satisfied with the evidence presented,103 the judge will sign the order and pass the signed order to counsel. Immediately following the prove-up hearing, each petitioner and counsel will sign the original and all copies of the order, if not signed prior to the hearing. It is best, of course, to sign all documents prior to the hearing, but because of the first-come, first-served basis, it may be more advisable to get the file in the stack before the docket is closed. Take the signed order the court clerk; leave all documents loose as each will need to stamped and signed. The court clerk will certify the court’s original order and will certify at least two (2) copy. Ask the clerk to certify all three (3) copies, but be advised that the clerk may ask for payment to certify the additional copies. The clerk will certify the copy by stamping the judge’s signature on the signature line, and stamping a certification on the back page of the order, which the court clerk will date and sign. It is absolutely imperative that one (1) original certified copy be included with the SIJS petition. Retain an additional copy for the client’s file, and another copy for the petitioner’s records.

L. Continuing, Exclusive Jurisdiction. The court acquires continuing, exclusive

jurisdiction of a SAPCR suit when the final order is rendered.104

103 Tex. Fam. Code § 105.005 (“[T]he court’s finding shall be based on a preponderance of the evidence”).

104 Tex. Fam. Code § 155.001(a). Although specific conditions trigger loss of continuing, exclusive jurisdiction, many of these circumstances are not relevant considerations in the context of SIJS. Id.


CHAPTER TWENTY-TWO

Special Immigrant Juvenile

Status (Family Law Portion)

Index of Appendices

Appendix 22-A Sample UCCJEA Affidavit

Appendix 22-B Sample Health Insurance Availability Form

Appendix 22-C Sample “Austin Form”

Appendix 22-D Sample Affidavit for Citation by Publication (Rule 109 Affidavit)

Appendix 22-E Sample Certificate of Attorney (Rule 239A Affidavit)

Appendix 22-F Sample Appointment of Attorney Ad Litem After Publication

Appendix 22-G Sample Attorney Ad Litem Statement of Evidence

Appendix 22-H Sample Prove-Up Preparation Questionnaire and Prove-Up Script


Appendix 22-A Sample UCCJEA Affidavit

CAUSE NO. ____________________

IN THE INTEREST OF § IN THE DISTRICT COURT

§

______________________ & § __________ JUDICIAL DISTRICT

___________________, §

§ _____________________, TEXAS

CHILDREN §

UNIFORM CHILD CUSTODY JURISDICTION AND ENFORCEMENT ACT

(UCCJEA) AFFIDAVIT

STATE OF TEXAS )

__________________ )

____________ appeared in person before me today and stated under oath:

“My name is _________. I am competent to make this affidavit. The facts stated in this

affidavit are within my personal knowledge and are true and correct.

“I am a Petitioner in this suit and a friend of the Children who are the subject of this suit.

____________ is the mother of the Children and _____________ is the father of the Children.

“The Child’s present address is ___________________________________, Texas

____________.

“The full legal name, place of birth, date of birth, and sex of the Children are:

Child’s Legal Name: _______________

Place of Birth: _______________

Date of Birth: _______________

Sex: _______________

Child’s Legal Name: _______________

Place of Birth: _______________

Date of Birth: _______________

Sex: _______________

“For the past _____ years immediately preceding the date of this affidavit, the Children

have lived with the following persons:


Address: ____________________________________________

Persons lived with: ____________________________________

Date: ______________

Address: ____________________________________________

Persons lived with: ____________________________________

Date: ______________

1. Participation in Custody Proceeding(s):

[√ one only]

_____I HAVE NOT participated as a party, witness, or in any capacity in any other

litigation or custody proceeding in Texas or any other state, concerning custody of or visitation a

child subject to this proceeding.

_____I HAVE participated as a party, witness, or in any capacity in any other litigation

or custody proceeding in this or another state, concerning custody of a child

subject to this proceeding.

Explain:

Name of each child:______________________________________________

Type of proceeding:______________________________________________

Court and state:_________________________________________________

Date of court order or judgment (if any):______________________________

2. Information about custody proceeding(s):

[√ one only]

_____I HAVE NO INFORMATION of any other proceeding that could affect this

proceeding, including proceedings for enforcement and proceedings relating to domestic

violence, protective orders, termination of parental rights, and adoptions in a court of this or any

other state concerning a child subject to this proceeding.

_____I HAVE THE FOLLOWING INFORMATION concerning a custody proceeding

pending in a court of this or another state concerning a child subject to this

proceeding, other than set out in item 2.

Explain:



Court and state:_________________________________________________

Date of court order or judgment (if any):______________________________

3. Persons not a party to this proceeding:

[√ one only]

_____I DO NOT KNOW OF ANY PERSON not a party to this proceeding who has

physical custody or claims to have custody of visitation rights with respect to the

child subject to this proceeding.

_____I KNOW THAT THE FOLLOWING NAMED PERSON(S) not a party to this

proceeding has (have) physical custody or claim(s) to have custody or visitation

rights with respect to any child subject to this proceeding:

Name and address of person:______________________________________

________________________________________________________________

( ) has physical custody ( ) claims custody rights ( ) claims visitation rights.

Name of each child:________________________________________________


Name and address of person: _____________________________________

________________________________________________________________


Name and address of person: _____________________________________

________________________________________________________________


4. Knowledge of prior child support proceedings:

[√ one only]

_____The Child described in this affidavit is NOT subject to existing child support

order(s) in Texas or any state or territory.

_____The child(ren) described in this affidavit are subject to the following existing child

support order(s):



Court and address:______________________________________________

Date of court order/judgment (if any):________________________________

Amount of child support paid and by whom:___________________________

____________________

AFFIANT

Sworn and subscribed to me this _____ day of ___________________.

____________________

Notary Public in and for

The State of Texas

[Stamped Notary Seal]


Appendix 22-B Sample Health Insurance Availability Form

CAUSE NO. ____________________


§

______________________ & § __________ JUDICIAL DISTRICT

___________________, §

§ _________________, TEXAS

CHILDREN §

HEALTH INSURANCE AVAILABILITY FORM

Attention: This information must be filed with the court BEFORE first hearing.

See TEX FAM CODE § 154.181(b).

NAME OF PARTY (OR PARTIES): ___________, Petitioner; and

___________, Petitioner

PARTY’S ATTORNEY (IF ANY): ___________

BESIDE THE NAME OF EACH CHILD, CHECK ALL TYPES OF HEALTH INSURANCE OR HEALTH CARE

BENEFITS CURRENTLY COVERING THE CHILD(REN). YOU MAY CHECK MORE THAN ONE SOURCE.

EMPLOYER PROVIDED NAME DOB SSN FATHER’S MOTHER’S PRIVATE CHIP OTHER NONE

________________ N/A [] [] [] [] [] []

________________ N/A [] [] [] [] [] []

FOR EACH INSURANCE SOURCE, PLEASE LIST THE FOLLOWING INFORMATION:

(ATTACH ADDITIONAL FORMS FOR EACH SOURCE OF BENEFITS)

A. NAME OF CARRIER:

B. GROUP POLICY ID NUMBER:

C. POLICYHOLDER NAME & ID NUMBER:

D. NAME OF COVERED CHILD:

E. COST/MONTH OF COVERAGE [CHILD(REN) ONLY] $

F. ARE YOU CURRENTLY PAYING THE PREMIUMS FOR LISTED MEDICAL BENEFITS? [] YES [] NO

STATE YOUR NET MONTHLY INCOME FROM YOUR FINANCIAL INFORMATION STATEMENT: $

SIGNATURE OF PARTY COMPLETING FORM DATE

PRINTED NAME


Appendix 22-C Austin Form


Appendix 22-D Sample Affidavit for Citation by Publication (Rule 109 Affidavit)

CAUSE NO. ______________


§

____________________, § __________ JUDICIAL DISTRICT

§

A CHILD § __________ COUNTY, TEXAS

AFFIDAVIT FOR CITATION BY PUBLICATION

BEFORE ME, the undersigned Notary Public, on this day personally appeared [Affiant

Name], who, being by me duly sworn on oath deposed and said that he has read this affidavit;

and that every statement contained in this affidavit is within his personal knowledge and is true

and correct.

1. Affiant is the attorney of record for the petitioners in this cause.

2. The residence of [Respondent’s Name], respondent in this cause and mother of the child,

is unknown to affiant and to the petitioners. After due diligence, affiant has been unable

to locate the whereabouts of the respondent, who was last known to reside in [City,

Country].

3. Affiant has taken the following specific actions in attempting to ascertain the

whereabouts of or locate the residence of the respondents:

a. Personal interview with the child in this matter on [date];

b. Personal interview with [responsible adult caregiver or family member] on [date];

c. Performed Internet searches for both Respondents on or about [date], but no

search returned any results for Respondent.


d. Researched the consulate-general in Houston, Texas, but found the consulate-

general unable to provide assistance in locating either Respondent.

4. This affidavit is made for the purpose of authorizing the clerk of this court to issue

citation for the named respondents by publication in accordance with the Texas Rules of

Civil Procedure.

____________________

AFFIANT

Sworn and subscribed to me this _____ day of ___________________.

____________________

Notary Public in and for

The State of Texas

[Stamped Notary Seal]


Appendix 22-E Sample Certificate of Attorney (Rule 239A Affidavit)

CAUSE NO. ____________________


§

[Child’s Name] § __________ JUDICIAL DISTRICT

§ __________ COUNTY, TEXAS

A CHILD §

CERTIFCATE OF ATTORNEY

Pursuant of Rule 239A, Texas Rules of Civil Procedure, I hereby certify that the last

know mailing address of the Respondent(s), is as follows:

[Respondent’s Name], Mother ADDRESS UNKNOWN

[Respondent’s Name], Father ADDRESS UNKNOWN

____________________

[Attorney’s Name]

State Bar No. ########

ATTORNEY FOR PETITIONERS

[Attorney Address, Telephone, Fax]


Appendix 22-F Sample Appointment of Attorney Ad Litem After Publication

CAUSE NO. _____________


§

______________________ & § ______ JUDICIAL DISTRICT

__________________, §

§ _____________, TEXAS

CHILDREN §

APPOINTMENT OF ATTORNEY AD LITEM AFTER PUBLICATION

The Court finds that __________ and ____________, Respondents and parties in this

case, have been cited by publication and that no answer has been filed and no appearance has

been entered by the party within the prescribed time.

The Court appoints ____________, a licensed attorney at law of this state, to defend the

suit on behalf of the party.

SIGNED on the _____ day of _________.

_____________________________

JUDGE PRESIDING


Appendix 22-G Sample Attorney Ad Litem Statement of Evidence

CAUSE NO. xx-xxxxx


§

FNAME LNAME § Number JUDICIAL DISTRICT

§

A CHILD § DALLAS COUNTY, TEXAS

STATEMENT OF EVIDENCE

On the date below the Court heard this case.

Petitioner appeared in person and through attorney of record, ______________. Respondents,

______________ and _____________, the natural parents of the children, were cited by publication,

failed to file a written answer in the case, and did not otherwise appear. The undersigned attorney ad

litem, a licensed attorney, was appointed by the Court to represent the interest of Respondents. The

parties announced ready for trial. All witnesses were sworn, and the case proceeded. The following

evidence was introduced:

The following unsuccessful attempts were made by the attorney ad litem to locate Respondents:

1. I interviewed the Petitioners, ___________ and ______________, and the two children,

_____________ and ____________, in their home on DATE. Each of the Petitioners and the children

stated that they did not know the location of either Respondent, but the Petitioners confirmed that the

Respondents likely reside somewhere in _________. Petitioners stated that they had attempted to locate

the Respondents through acquaintances, friends, and relatives in __________, but had been unable to do

so. Petitioners stated that neither Respondent has attempted to contact them about the welfare of the

children at any time (beyond the initial contact at each child’s birth), and the Petitioners and the children

confirmed that neither Respondent has expressed a desire to be a part of the children’s lives. Petitioners

also confirmed that neither Respondent has provided forwarding information. Petitioners stated that they

have no information, and have had no information since the children’s births, regarding the whereabouts

of Respondent ________. Petitioner __________ confirmed that, though she is the sister of Respondent

_________, their mother has passed away and their father is in a coma, and there are no other siblings


through whom they could locate Respondent ___________, and none of their other relatives has

information regarding Respondents’ whereabouts. Finally, Petitioners and the children stated that they

did not have any additional information that might lead to the whereabouts of Respondents.

2. Petitioner ____________ and I also corresponded via email during DATE. In that

correspondence, Petitioner ____________ stated that the Petitioners have attempted to contact the

Respondents on numerous occasions throughout the children’s lives, both before and after the children

arrived in the United States. He stated that the Petitioners have on several occasions contacted business

and family friends in their attempts to locate Respondents, all with no success. Petitioner _________ also

stated that Petitioners have told their friends to give Respondent __________ their contact information

should they ever locate Respondent, but they have had no response. He also stated that he and his wife

were well-known members of the community in ________, and that Respondents could have easily

located them. Petitioner __________ also stated that Respondent _____________has no government

identification or driver’s license that they could use to find him, nor has Respondent _________ been

listed in a phone book. Petitioner _________ further stated that, according to the most recent information

Petitioners have, Respondent __________ has moved to the border area of __________, but they do not

have more specific information, and their attempts to find him in the directories of all the major cities and

some of the smaller towns have been unsuccessful.

3. I do not know the residence of either Respondent.

4. I performed Internet searches for both Respondents, but neither search returned any

results for either Respondent.

5. I contacted the consulate-general in ______ and the ________ Embassy in ___________.

on numerous occasions and spoke with several individuals, none of whom was able to provide assistance

in locating either Respondent.

Respondents were served with citation by publication by the clerk of this Court by having the

citation published on _____________ in the _______________. The citation was returned to the Court.


APPROVED on [DATE].

________________________

JUDGE PRESIDING

I have read the foregoing and agree that it accurately represents the evidence introduced at the

hearing described above.

By: ____________________

State Bar No. _________

Attorney for Petitioners

By: ____________________ State Bar No. _________

Attorney Ad Litem


Appendix 22-H Sample Prove-Up Preparation Questionnaire and Prove-Up Script

QUESTIONNAIRE

1. Please provide the following personal information:

a. Name

b. Residence Address

c. Mailing Address (if different from residence address)

d. Telephone Number

e. Social Security Number

f. Driver License Number, State of Issue

g. Name of Employer

h. Employer Address

i. Employer Telephone Number

2. Please briefly describe:

a. How you met the child

b. Duration and circumstances of the child’s stay with you

c. Care and support you provide

3. Please provide the following information to the best of your ability:

a. Knowledge of child’s parent(s) or family members whereabouts, if any

b. Contact with child’s parent(s) or family members, if any

c. Attempts to locate or contact child’s parent(s) or family members, if any

4. Please provide any additional information or documentation that you believe is important or to be

helpful in this case.

5. Please read and review the “Prove-Up Questions”.


PROVE-UP SCRIPT

1. Biographical

a. Name

b. Address

c. How long have you lived at that address?

2. Relationship With Child

a. Is it true that you are the biological aunt of the Child?

b. How long have you known him/her?

c. Does he/she live with you? If so, how long?

3. Knowledge of Child’s Background

a. Prior Residence

i. Where did the Child live before he/she came to your home?

ii. Is it true that the child was hit by her caretaker in that home?

iii. Is it true that this happened for a number of years?

iv. Is it true that you did not know about this until the child came to live with you?

b. Family Background

i. Father

1. What do you know of the Child’s father?

2. Do you know where he is?

3. When is the last time you heard from him?

4. Is it true he has not had contact with the child for at least the last 10

years?

ii. Mother

1. What do you know of the Child’s mother?

2. Do you know where she is?

3. Is it true that she has not had contact with the child for at least 2 years?

4. Is it true that you believe she is deceased?

5. Is this because she was taken from the home by gunpoint by gang

members?

4. Support of Child

a. Have you provided support for the Child (e.g. food, clothing, and shelter; medical)?

b. Will you continue to provide this support to the Child?

5. Best Interest Not to Return

a. Is there anyone who could provide support for the Child in Honduras?

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