See In re Tex. Dep't of Fam. &Protective Servs., 255 S.W.3d 613, 615 (Tex. 2008) (orig. proceeding) (per curiam); In re Justin M., 549 S.W.3d 330, 334 (Tex. App.-Texarkana 2018, orig. proceeding); In re M.N.M., 524 S.W.3d 396, 399 (Tex. App.-Houston [14th Dist.] 2017, orig. proceeding); see also In re J.D.S., 494 S.W.3d 387, 389-90 (Tex. App.-Waco 2015, no pet.) (explaining that the trial court's decision to allow the Department to maintain custody of a child following a full adversary hearing is reviewable by mandamus and that any temporary order making findings to support removal will be superseded by the entry of a final order of termination).

The "Department and the trial court retain authority to address subsequent conduct by Mother and Father as appropriate." In re M.N.M., 524 S.W.3d 396, 405 (Tex. App.—Houston [14th Dist.] 2017, orig. proceeding). The Family Code gives the district court broad authority to protect children short of separating them from their parents and this likewise includes a range of mechanisms to address a parent's controlled substance abuse.

Id. § 262.201(g)(2); see In re Tex. Dep't of Fam. & Protective Servs., 255 S.W.3d 613, 615 (Tex. 2008) (orig. proceeding) (per curiam); In re M.N.M., 524 S.W.3d 396, 402 (Tex. App.-Houston [14th Dist.] 2017, orig. proceeding).The adversary hearing affords parents the opportunity to present evidence on their own behalf, hear and challenge the Department's evidence, and contest the Department's right to maintain possession of their children.

Id. § 262.201(g)(2); see In re Tex. Dep't of Fam. & Protective Servs., 255 S.W.3d 613, 615 (Tex. 2008) (orig. proceeding) (per curiam); In re M.N.M., 524 S.W.3d 396, 402 (Tex. App.—Houston [14th Dist.] 2017, orig. proceeding); but see In re C.T., 491 S.W.3d 323, 328 (Tex. 2016) (orig. proceeding) (noting that "[§] 262.201 does not specify who bears the burden of proof on the legal-entitlement issue").

As it pertains to this case, mandamus relief may be available to review a trial court's ruling under § 262.201. See In re M.N.M., 524 S.W.3d 396, 399 (Tex. App.—Houston [14th Dist.] 2017, orig. proceeding); In re Hughes, 446 S.W.3d 859, 860 (Tex. App.—Texarkana 2014, orig. proceeding). The Court, having examined and fully considered the petition for writ of mandamus and the applicable law, is of the opinion that the relator has failed to meet her burden to obtain relief.

Mother acknowledges that the Department is not expected to ignore a positive drug test. See In re M.N.M., 524 S.W.3d 396, 405 (Tex. App.—Houston [14th Dist.] 2017, orig. proceeding) ("The Department could not ignore a pre-removal hair follicle test that came back positive or the results of post-removal drug tests[.]"). On the other hand, "the Texas Family Code provides a range of mechanisms to address controlled substance abuse by parents."