The child in a pending CPS case was the subject of a prior CPS case about 11 or 12 years ago. In the prior case, the father executed a voluntary relinquishment of his rights. The court did not terminate his rights in the prior case.

Given that the voluntary relinquishment states that it is irrevocable, could that be used in our current case, should we decide to seek termination? The father's current location is unknown, and he is not participating in our case at this point.

I used to do those cases and I do not have a family code in my office anymore. Your best bet is to get on texas lawyers for children's forum and post this question. You will get a large number of responses.

I don't know of any law on that issue, but I wouldn't feel comfortable using a 12 year old relinquishment in one of my cases. Surely you have constructive abandonment if it has been that long and he isn't in the child's life any more. You may have to do a publication to serve him which will take longer, but I think that's the cleaner way to go.