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CPS reform

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156 S.W.3d 574 IN RE S.A.P.
135 S.W. 3d 165 IN RE S.A.P.
80 S.W. 3d 232 IN RE J.M.M
963 S.W. 2d 550 Avery vs. State

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7.There was no complaint in B.L.D. that valid and invalid theories of liability were submit­ted in a single broad-form submission as in Crown Life. The B.L.D. majority's only rele­vant legal discussion of Crown Life is: "After Crown Life, the submission of disjunctive broad-form questions in termination cases, at least without appropriate instructions to guard against a less-than-consensus verdict, is no longer automatic." 56 S.W.3d at 216.





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