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.”