Family Code 85.005 authorizes agreed orders under 85.022 if approved by the ct. but in the same paragraph precludes an agreement that requires anything under 85.022. I thought it was a typo, but In re I.E.W., 082710 TXCA13, 13-09-00216-CV considers the apparent paradox correct. Does that mean that 85.022 terms are OK, but only if the ct. holds an adversarial hearing?

Watch the language on who it applies to. You can have an agreed order, but that agreed order may only apply to the respondent, not the applicant. (e.g.- if you have an agreed order it can't say "Both applicant and respondent are barred from contacting the other party.") This is simply to back up the provisions of 85.003 that require separate protective orders for each party.

To the extent that IEW touches 85.005, it clarifies that an agreement of the order does not relieve the court of the requirement of finding family violence has occurred and is likely to occur in the future.

Fully understand. Thanks for making it so clear.