In In re B.L.D., 56 S.W.3d 203 (Tex. App.--Waco 2001), rev'd, 113 S.W.3d 340 (Tex. 2003) the court of appeals reviewed the unpreserved complaint, holding that "procedural due process concerns required review of 'core issues' in the jury charge in involuntary termination cases even when the parties failed to object to the charge at the trial court." Id.
In reversing, the Texas Supreme Court held that the fundamental-error doctrine does not permit, and due process does not require, "appellate courts to review unpreserved complaints of charge error in parental rights termination cases." Id. at 351, 354.