On May 6, 2020, Sonia filed an original petition in a suit affecting the parent child relationship in Kleberg County, Texas, alleging that she had exercised "actual possession and control of [A.N.G.] since June 1, 2019." The petition states that A.N.G. was born on November 20, 2012, and identifies the respondent as Sonia's son and A.N.G.'s father, Crispin Gonzales IV. Sonia's original petition requested the trial court to, inter alia, appoint Sonia, relator, and Crispin as joint managing conservators; to designate Sonia as the conservator with the exclusive right to designate A.N.G.'s primary residence; to limit the residence of A.N.G. to Kleberg County and contiguous counties; and to award Sonia the exclusive right to enroll A.N.G. in school. Sonia's original petition was supported by her May 6, 2020 affidavit stating, in relevant part:
[A.N.G.] has been in my physical care and possession since June 1, 2019. Her father signed an Authorization Agreement for Voluntary Caregiver, so I was able to enroll her at Jubilee Academy for the school year 2019-2020. During the past eleven months I have provided for [A.N.G.'s] physical and emotional needs. While providing food, shelter, clothing, medical care, loving support, and guidance. [sic]I have the ability to drop her off and pick her up at school or aftercare. Her educational needs are being met with perfect attendance[,] and [she] excels in school as evidence[d] in her school grades.
Her father works in Pennsylvania 14 days on and 14 days off. He exercises possession of her on his days off. Her mother[, relator] lives in Jacksonville, Florida. On May 30, 2019[,] I went to Florida and picked [A.N.G.] up for the summer with the understanding that her mother would be moving to Texas before the beginning of the school year. On or about June 2, 2019[,] I was advised by [relator] that she would not be moving to Texas as intended but that [A.N.G.] may remain here in Texas and could start school here until she moved here at a later date, or before the end of the year. [Relator] has electronic communication with [A.N.G.] anytime she wants to supplement her periods of possession.
During the past eleven months, [A.N.G.] has adapted well with her surrounding environment and extended family here in Texas. [A.N.G.] loves it here and is expecting to possibly visit Florida for the summer and return before the new school year. Removing [A.N.G.] from her present environment would not be in [her] best interest but would affect her physical and emotional well-being.
On August 25, 2020, relator filed a verified "Special Appearance, Plea to the Jurisdiction, Request to Decline Jurisdiction, and Original Answer." She asserted that the trial court lacked jurisdiction over her because she resided in Florida, and that Texas lacked subject matter jurisdiction over the case under Texas Family Code § 152.201 because Florida was the "home state" of A.N.G.:
4. The "home state" of the child the subject of this suit is in Florida. The child's parents entered into an informal co-parenting agreement, in which [relator] allowed [Crispin], [A.N.G.'s] putative father, to have temporary possession of the child for one school term. The parties understood and agreed that at the conclusion of the school year, the child would be promptly returned to [relator] in Florida. During the time that the child was staying with her putative father, she was bounced around from home to home and eventually began living with an uncle in February of 2020. The mere presence of the child in Texas was a temporary arrangement and all parties agreed and understood that the child would be returned to [relator] at the conclusion of the school year, and the child was returned as agreedon May 19, 2020. Since that time, the child [who is] the subject of this suit has been living in Florida with [relator].
In connection with her jurisdictional argument, relator also assailed Sonia's standing to bring suit on grounds that she did not have possession of the child for at least six months.3 Relator further asserted, alternatively, that the trial court should decline to exercise jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) because the Texas forum was inconvenient, and Florida constituted a more appropriate forum:
11. Here, the Court should decline jurisdiction over this child custody proceeding because an application of the factors enumerated under [§] 152.207 of the Texas Family Code, demonstrate[s] that Florida is the more appropriate forum. As detailed in the Affidavit of [relator], neither of the child's parents presently reside or have past contact with Texas. [Relator] has resided with [A.N.G.] in Florida since 2015, and her putative father, [Crispin], presently works and lives primarily in Pennsylvania. [Crispin] has had past contacts with Florida and is subject to the jurisdiction of the Florida courts. [Crispin] and [Sonia] were both in Florida as recently as August 8, 2020. [Crispin] and [Sonia] were in Florida for purposes of harassing [relator] and Florida law enforcement had to be called to respond to the incident. The Florida police records and officers that witnessed the encounter are in Florida. Further, there [have] been past instances of domestic abuse by [Crispin], as described by the affidavit of [relator]. The concern in this case is that [Crispin] and [Sonia] could again engage in behavior to disrupt the peace of [relator] and [A.N.G.]. Florida would be the state in the best position to protect the parties[] based on their past contact with that state. Additionally, and as referenced herein, there is presently a pending lawsuit between [Crispin] and [relator] in Jacksonville, Florida, and the court hearing the matter has jurisdiction and the ability to enter appropriate orders concerning the conduct of the parties. Florida and its courts are the appropriate forum with regard to protecting the parties as described by TEX. FAM. CODE [ANN.] § 152.207(b)(1). . . .
12. [A.N.G.] was conceived and born in the State of Virginia. [A.N.G.] has always lived primarily with her mother, [relator]. [Relator] raised [A.N.G.] since the time the child was born November 20, 2012 to the present. [Relator] and [A.N.G.] resided in Virginia together from November 20, 2012 to April 2015. Thereafter, [relator] moved with [A.N.G.] to Florida to be closer to [relator's] immediate and extended family and friends. [Relator] and [A.N.G.] have resided together in Florida since moving there back in April of 2015. [A.N.G.] was merely present in Texas pursuant to an agreement between the parties whereby it was understood and agreed that [A.N.G.] would remain with [Crispin] for the duration of one school year. [Relator] agreed to allow [A.N.G.] to stay with [Crispin] to make up for lost time when he was not involved in [A.N.G.'s] life. [A.N.G.] has resided outside of Texas her entire life and was merely present in Texas due to this temporary possession arrangement. Here, the length of time that [A.N.G.] has resided outside of Texas demonstrates that Florida is the appropriate forum for this proceeding. TEX. FAM. CODE [ANN.] § 152.207(b)(2) (the court must consider the . . . time the child resided outside Texas when determining whether another court is a more appropriate forum). The duration in which [A.N.G.] has resided outside of Texas in this case supports the decision that it is appropriate that this Court decline jurisdiction based inconvenient forum. Id. . . .
13. Further, Florida is a more appropriate forum in this Case because the parties and the child the subject of the suit reside in or are closer to Florida. The evidence and testimony regarding the growth, historical development and parental needs and relationship with the child exists almost entirely in the State of Florida. [Relator] and [A.N.G.] have lived together in Florida since April 2015. [Crispin] presently works and lives in Pennsylvania. The distance between each forum state further demonstrates how Florida would be the more appropriate forum. Further, as discussed in the Affidavit of [relator], litigating and eventually trying this matter before jury would cause her to incur undue financial hardship in traveling to and from Texas and would disrupt [A.N.G.]'s daily life and routine, which would not be in her best interest and would unfairly prevent [relator] from adjudicating these claims. The relevant distance and evidence in this proceeding demonstrates that Florida is a more appropriate forum for this case. TEX. FAM. CODE [ANN.] § 152.2(07(b)(3). . . .
14. Moreover, [relator's] present financial circumstances prevent her from fairly litigating these claims in Texas. [Crispin], including as evidenced
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