Thomas J. Daley
Thomas J. DaleyKoonsFuller, P.C. - Texas Family Law Powerhouse
Litigation StrategiesOpinion LibraryOur TeamFAQConsultation
Litigation StrategiesOpinion LibraryOur TeamFAQ
FAQ/Question

Can my lawyer withdraw from my juvenile case during commitment or modification proceedings?

This question has been addressed in 1 Texas court opinion:

COA10 — February 5, 2026

In this juvenile delinquency proceeding, S.W. appealed an order committing her to the Texas Juvenile Justice Department. Her court-appointed attorney filed an Anders brief asserting the appeal was frivolous and a motion to withdraw. The Tenth Court of Appeals analyzed Texas Family Code § 51.101(a), which requires counsel appointed at the initial detention stage to represent the child 'until the case is terminated.' Drawing a parallel to the Texas Supreme Court’s 'continuing duty' doctrine in parental rights termination cases (In re P.M.), the court interpreted 'termination' to mean the exhaustion of all appeals through the Texas Supreme Court. Consequently, while the court affirmed the commitment order, it denied the attorney's motion to withdraw.

Litigation Takeaway

“Attorneys appointed at the initial detention stage of a juvenile case under Texas Family Code § 51.101(a) are tethered to the case through the exhaustion of all appeals. Even if an appeal is found to be meritless under Anders, the attorney’s statutory duty does not end until the right to pursue a petition for review in the Texas Supreme Court is satisfied or waived.”

Thomas J. Daley

Texas Family Law Litigation

Sophisticated litigation strategies for Texas families. Experience, integrity, and results when it matters most.

Targeted Resources

  • Divorcing a Narcissist
  • Dividing Retirement Assets
  • Fathers' Involvement
  • High-Asset Divorce

Contact Info

  • 1-972-769-2727
  • tdaley@txfamlaw.com
  • 5700 W. Plano Parkway Ste 2200, Plano, TX 75093
© 2026 JDBOT.US, LLC. All Rights Reserved. Attorney Advertising.
Information provided on this site is for educational purposes only and does not constitute an attorney-client relationship.
Created with by Thomas J. Daley
Attorney Login