C. De Novo Hearing vs. Trial De Novo

The Supreme Court of Texas has held that neither Section 201.015 nor any other provision of the Texas Family Code expressly confers a right to a jury trial in a de novo hearing.[50] That A.L.M.-F case distinguishes a De Novo Hearing and a Trial De Novo. A “trial de novo” is a new and independent action in the reviewing court with “all the attributes of an original action” as if no trial of any kind has occurred in the court below.[51] But under Chapter 201, a hearing is not equivalent to a trial, and review under section 201.015 is not entirely independent of the proceedings before the associate judge. Accordingly, the term “de novo hearing,” as used in Chapter 201, does not equate to a “trial de novo.” Rather, the term “de novo hearing” has meaning that is unique to the associate judge referral statutes and governed by the procedures specified in the authorizing statutes.[52]