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Click here for the full text of this decision FACTS:The appellee, Jackie Williams, filed a petition to terminate the parent-child relationship between appellant Lydia Williams and her daughter, K.W. When Lydia failed to answer, the trial court granted a default judgment, terminating Lydia’s parental rights. Lydia timely filed a motion for new trial, which the trial court overruled. She now appeals. HOLDING:Reversed and remanded. The citation fails to include Jackie’s name but complies with Rule 99 in all other respects. Instead of naming the parties, the citation includes the style of the case. It also correctly identifies Lydia and includes the name and address of Jackie’s attorney. Jackie is named as the petitioner in the original petition to terminate the parent-child relationship, which was attached to the citation. Lydia does not claim on appeal that she was not properly identified on the citation. Nor does she claim that she was not served. Indeed, she filed an answer with the trial court, albeit after the court rendered judgment. Her complaint is that the citation did not include the name of Jackie, who was a party to the dispute, and therefore did not strictly comply with the rules of civil procedure. This state’s jurisprudence requires strict adherence to the rules regarding service of citation, it does so to ensure that there is no question about whether the proper party has been served before a default judgment is rendered. Here, however, not only does the return reflect that Lydia was properly served, but Lydia admitted that she was properly served throughout her testimony during the motion for new trial hearing. She testified that she was served while she was in jail, that she carefully read all of “the papers” that were served on her in jail, and that she immediately contacted her father after she was served. Furthermore, when asked how she discovered the names of the prospective adoptive parents, she answered that their names were in “the papers I was served.” Finally, in her affidavit supporting her motion for new trial, Lydia averred that she was served while in jail, that her mother was the petitioner in the petition to terminate Lydia’s parental rights, and that she drafted a response to the petition two weeks after she was served, but did not mail it until after the default judgment was rendered. Not only did her testimony make clear that she was properly served, but she also knew who the petitioner was in this suit. In light of the fact that there is no dispute as to whether Lydia was properly served and that the record establishes that she was aware of who filed the suit, the court holds that the trial court did not err in assuming personal jurisdiction over Lydia. Lydia also relies on Rule of Civil Procedure 15 in support of her argument. That rule instructs that “process shall be directed to any sheriff or any constable within the State of Texas.” Tex. R. Civ. P. 15. Citing Barker CATV Construction Inc. v. Ampro Inc., 989 S.W.2d 789 (Tex. App. � Houston [1st Dist.] 1999, no pet.), Lydia argues that Rule 15, when coupled with Rule 99b, which addresses the issuance and form of citation, requires the citation be addressed to both the defendant and a constable or sheriff. The court disagrees. Like the court in Barker CATV Constr. Inc. v. Ampro Inc., 989 S.W.2d 789 (Tex. App. � Houston [1st Dist.] 1999, no pet.), this court holds that citations must be expressly directed to the defendant under Rule 99 and may also be addressed to the sheriff or constable under Rule 15, but failure to include the sheriff or constable on the form of the citation will not render it void. Because the citation in this case was directed to Lydia, the defendant, the court holds that the citation was not void. The termination of parental rights is unlike a traditional civil case, involving only two competing interests, the plaintiff’s and the defendant’s. The child’s interest must also be considered and indeed is of paramount importance. The traditional no-answer default judgment rule takes into consideration only the actions of the defaulting parent; it leaves no room for the trial court to consider the child’s best interest. Thus, in light of the special characteristics of termination proceedings and the important interests they are designed to protect, the court holds that the traditional rule � that evidence is unnecessary to support a default judgment because the failure to answer is taken as an admission of the allegations in the petition � does not apply to involuntary termination of parental rights proceedings. OPINION:Puryear, J.; Law, Smith and Puryear, JJ.

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