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CPS reform


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


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.


How could this happen to me