Opinion issued June 29, 2023

In The Court of Appeals For The First District of Texas ———————————— NO. 01-23-00445-CV ——————————— IN RE F.N.M., Relator

Original Proceeding on Petition for Writ of Mandamus

MEMORANDUM OPINION Relator, F.N.M., has filed a petition for writ of mandamus challenging the trial court’s pretrial determination regarding the burden of proof applicable for an affiant to establish that an affidavit under Section 161.103 of the Texas Family Code was procured by fraud, duress, or coercion.1 We deny the petition.

PER CURIAM Panel consists of Justices Goodman, Landau, and Rivas-Molloy.

The underlying case is In the Interest of A.M.M., a Child, cause number 2019-75952, pending in the 312th District Court of Harris County, Texas, the Honorable Teresa Waldrop presiding.