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In Re Steven Broomfield and Lisa Broomfield v. State of Texas - Mandamus

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Filed March 16th, 2026
Detected March 18th, 2026
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Summary

The Texas Court of Appeals denied a petition for a writ of mandamus, application for emergency habeas relief, and motion to declare contempt void. The court found that the trial court did not err in denying the motion to transfer due to the relators' conduct.

What changed

The Texas Court of Appeals, Sixth District, denied a petition for a writ of mandamus filed by Steven and Lisa Broomfield. The relators sought to compel the trial court to transfer a case and to prohibit further exercise of jurisdiction, arguing the trial court impermissibly denied their motion to transfer. The court found that the trial court did not err in its decision due to the relators' unjustifiable conduct.

This ruling means the relators' requests for mandamus relief and emergency habeas relief have been denied. The case will proceed in the trial court as previously ordered. No specific compliance actions are required for external parties, as this is a judicial decision regarding a specific case. The disposition indicates the relators' arguments were unsuccessful.

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March 16, 2026 Get Citation Alerts Download PDF Add Note

In Re Steven Broomfield and Lisa Broomfield v. the State of Texas

Texas Court of Appeals, 6th District (Texarkana)

Disposition

Motion or Writ Denied

Lead Opinion

In the
Court of Appeals
Sixth Appellate District of Texas at Texarkana

No. 06-26-00023-CV

IN RE STEVEN BROOMFIELD AND LISA BROOMFIELD

Original Mandamus Proceeding

Before Stevens, C.J., van Cleef and Rambin, JJ.
Memorandum Opinion by Chief Justice Stevens
MEMORANDUM OPINION

Relators, Steven Broomfield and Lisa Broomfield, have filed an “Emergency Petition for

[a] Writ of Mandamus,” “Application for Emergency Habeas Relief,” and “Motion to Declare

Contempt Void for Lack of Jurisdiction.” Relators’ petition for a writ of mandamus asks this

Court “to compel the trial court to perform its ministerial duty to transfer the case and to prohibit

further exercise of jurisdiction beyond that act.” As to their habeas request, Relators further

request emergency habeas relief for Steven, who they argue is being “held unjustly,” and they

further seek “an order declaring void any orders of the trial court made after the trial court

impermissibly denied Relators’ motion to transfer.” Because we hold that the trial court did not

err in denying Relators’ motion to transfer due to Relators engaging in unjustifiable conduct in

moving B.B.J.1 against court orders, we deny all requested relief.

“Mandamus relief is an extraordinary remedy available only on a showing that (1) the

trial court clearly abused its discretion and (2) the party seeking relief lacks an adequate remedy

on appeal.” In re Ill. Nat’l Ins. Co., 685 S.W.3d 826, 834 (Tex. 2024) (orig. proceeding). “The

relator is obligated to provide this Court with a record sufficient to establish his right to

mandamus relief.” In re Shugart, 528 S.W.3d 794, 795 (Tex. App.—Texarkana 2017, orig.

proceeding) (citing Walker v. Packer, 827 S.W.3d 833, 837 (Tex. 1992) (orig. proceeding); TEX.

R. APP. P. 52.3).

The underlying suit affecting the parent-child relationship (SAPCR) was filed in Panola

County. On August 29, 2023, the Honorable Rick McPherson, sitting judge in the County Court

1
To protect the child’s identity, we use initials for the child and for his family members. See TEX. R. APP. P. 9.8.
2
at Law (CCL) of Panola County, entered an order by letter, which included a residence

restriction, requiring that B.B.J. remain in Panola County or “any county in Texas contiguous to

Panola County.” On December 2, 2025, Relators filed an original petition seeking to terminate

the parental rights of B.B.J.’s biological parents and further seeking adoption of B.B.J. in Smith

County, where they alleged they had lived with B.B.J. for the preceding six months. Relators

then filed a “Motion for Mandatory Transfer of Venue” under Sections 155.201 and 155.204 of

the Texas Family Code, stating that B.B.J. had been a resident of Smith County for more than six

months. See TEX. FAM. CODE ANN. §§ 155.201, 155.204 (Supp.)

The Panola County CCL “heard the evidence on Movant [C.A.’s] Third Amended

Motion for Enforcement of Possession and Access” and found that Judge McPherson’s August

29, 2023, letter was a valid and enforceable order and that Relators had thirty-six violations as to

the orders of the court. The Panola County CCL stated that Relators

are hereby found in violation of court orders as set out above. For each of these
36 violations, [Relators] are hereby held in Contempt and are sentenced to 60
days in the Panola County Jail for each violation to run concurrently. [Relators]
are hereby ordered to serve 10 days of that sentence upfront with the remaining 50
days probated for ten years under the supervision of the Panola County
Community Supervision Department. Further, once [Relators] have completed
the above 10-day jail term, each shall post a $1000 cash bond as security for
compliance with the Court’s order granting possession of or access to the child.

A hearing was scheduled for December 22, 2025. It was noted, via email, that the ten-day jail

sentence for Relators would begin that day. C.A. subsequently filed a controverting affidavit

related to Relators’ motion for mandatory transfer, in which she stated that she remained living

in Panola County and did not consent to the move of B.B.J. outside of the geographic area set by

3
the trial court’s order.2 While Relators did not provide a copy of the order, they state that the

motion to transfer venue was denied on February 16, 2026, and subsequently, on a new motion

to enforce, the trial court found that Relators remained in contempt of court and issued an order

for their arrest and confinement for the remainder of their sentence, fifty days. Steven is

currently being held in the Panola County Jail, and capias was issued for the arrest of Lisa.

Regardless of whether [Real Party’s] affidavit controverting was sufficient, the
question before us is whether transfer of venue to a county not authorized by the
existing custody order is proper. We recognize that transfer of a case to a county
where the child has resided for more than six months is a mandatory ministerial
duty under section 155.201 of the Family Code. See TEX. FAM. CODE ANN.
§ 155.201; see also Proffer v. Yates, 734 S.W.2d 671, 673 (Tex. 1987)
[(per curiam) (orig. proceeding)]. But before a trial court transfers venue, a
proper county for transfer must be identified. Huey v. Huey, 200 S.W.3d 851, 853
(Tex. App.—Dallas 2006, no pet.). Venue is a matter of personal privilege that a
party may expressly or impliedly waive. Id.

In re Christon, 698 S.W.3d 597, 599 (Tex. App.—Waco 2024, orig. proceeding). Here, as in

In re Christon, there was a SAPCR order in effect which contained a geographic restriction, and

because of that restriction, Smith County is not an authorized county to establish B.B.J.’s

residence. See id. at 599–600. There was never a motion filed to modify the geographic

restriction. Relators’ conduct was an attempt to establish B.B.J.’s residence and thus venue in a

county barred by the underlying SAPCR orders. As such, we conclude that Smith County is not

the proper county to which transfer must be made by the trial court that maintains continuing,

exclusive jurisdiction. See id. (citing Huey, 200 S.W.3d at 853).

2
Relators state that they were both committed to the Panola County Jail for a period of ten days pursuant to the
contempt order. Relators filed a petition for a writ of mandamus and sought habeas relief, which was denied. In re
Broomfield, No. 06-25-00135-CV, 2025 WL 3718400, at *2 (Tex. App.—Texarkana Dec. 22, 2025, orig.
proceeding) (mem. op.). Relators also filed a petition for a writ of mandamus seeking to have the trial court rule on
their transfer of venue motion, which was also denied. In re Broomfield, No. 06-26-00004-CV, 2026 WL 308318, at
*2 (Tex. App.—Texarkana Feb. 5, 2026, orig. proceeding) (mem. op.).
4
Because the trial court was not required to transfer the matter to a county without proper

jurisdiction, the trial court in Panola County maintained jurisdiction over this matter, and

Relators’ arguments that any orders entered after they moved to transfer venue are not

persuasive. Accordingly, we deny Relators’ petition for a writ of mandamus.

Relators also attack the credibility of the trial court’s contempt order and seek habeas

relief and the immediate release of Steven. “As a general rule, the validity of a contempt

judgment can only be attacked collaterally by habeas corpus.” Ex parte Sealy, 870 S.W.2d 663,

666 (Tex. App.—Houston [1st Dist.] 1994, no writ) (citing Deramus v. Thornton, 333 S.W.2d

824, 827 (Tex. 1960) (orig. proceeding)). “In such a review, the appellate court is limited to the

determination of whether the commitment order is void.” Id. (citing Doss v. Doss, 521 S.W.2d

709, 711 (Tex. App.—Houston [14th Dist.] 1975, no writ)).

Relators’ actions in moving B.B.J. outside of the geographic restriction were an

intentional violation of the trial court’s order. Relators argue that the trial court was devoid of

jurisdiction to enter any orders of contempt once they initiated a mandatory transfer. However,

having already determined that the trial court did not err in failing to transfer this matter to Smith

County, we find that the trial court’s jurisdiction remained intact when it rendered the order of

contempt. We deny Relators’ request for habeas relief.

5
Relators’ petition for a writ of mandamus is denied.

Scott E. Stevens
Chief Justice

Date Submitted: March 13, 2026
Date Decided: March 16, 2026

6

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
TX Courts
Filed
March 16th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Legal professionals
Geographic scope
State (Texas)

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Appellate Procedure Civil Procedure

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