The Second Court of Appeals in Fort Worth granted a mandamus on February 4th, 2002 in a case by the Texas Department of Protective and Regulatory Services for termination of parental rights. See In Re Texas Department of Protective and Regulatory Services, No. 2-02-0002-CV.

The case involved parents that were facing criminal charges for injuries to their child. The trial court stayed the proceedings prior to the September 1, 2001 changes to the Texas Family Code, Sec. 161.2011, because of the criminal charges, and refused to lift the stay after the new laws were effective.

The Court of Appeals held that the amendment to Section 161.2011 applies to all TDPRS cases regardless of their current status, i.e. stayed.