In re Tinker’s Empirical Analysis

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1 state decisions

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1. “under family code section 102.004(b), the trial court may grant leave to intervene to grandparents and those 'deemed by the court to have had substantial past contact with the child.' " See In re A.G. , No. 05-18-00725-CV, 2018 WL 6521893 , at (Tex. App.-Dallas Dec. 12, 2018, no pet.) (mem. op.) (applying section 102.004(b) to non-parent with whom child had been placed by CPS for two weeks); In re L.S.B. , No. 05-17-00929-CV, 2018 WL 3598958 , at (Tex. App.-Dallas July 27, 2018, no pet.) (mem. op.) (applying section 102.004(b) to non-parent with whom child had been placed by CPS for three months). We also recognize the opinion of one of our sister courts of appeals concluding intervening grandparents lacked standing because they failed to establish substantial past contact, but that opinion did not include any analysis as to whether grandparents as opposed to "other persons”

   1 later decision quote this exact passage · from the majority
   e.g. In re Nelke