Bland Indep. Sch. Dist. v. Blue
In Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 553-54, 44 Tex. Sup. Ct. J. 125 (Tex. 2000), the Texas Supreme Court recognized the importance in considering evidence in determining "associational standing" for purposes of deciding whether an organization has standing to assert claims on behalf of its members. 34 S.W.3d at 553-54.
If evidence is important in determining "associational standing" in a business context, it is even more important in resolving grandparents' standing in a family law context.
Furthermore, if standing is asserted under section 102.004 of the Texas Family Code, the grandparents must provide "satisfactory proof" to the court that standing exists. See TEX. FAM. CODE ANN. 102.004 (Vernon 2002).
If no evidentiary hearing is conducted, the grandparents necessarily could not have provided the trial court with "satisfactory proof." See id.