The case of the day is In re JR (Tex. Ct. App. 2019). The Texas Department of Family and Protective Services sought to terminate the parental rights of a father over his child in Texas. The father resided in Mexico. His address was unknown, so the court authorized “service by posting,” which is what Texas calls notification au parquet. The summons, apparently, is “posted” at the courthouse. The case went to trial, and the father moved for a directed verdict on the grounds that he had not been properly served with trial. At some point, the Department uncovered the father’s address in Mexico, though it’s not really clear when that happened. The court denied the motion and ruled against the father on the merits,…

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