In re J.L.W.

I write not in disagreement with the majority opinion,1 but to note the inconsistency in the law regarding the interpretation of the word “shall.” It appears to me that the definition of “shall” depends on the area of law. As such, judges are left wondering what the word means in a wide variety of contexts. Just within the Family Code, many resources are spent determining what the word means in each particular code section. After extensive analysis of the legislative history behind the specific Family Code section, Courts often construe the word to be mandatory. See, e.g., Voros v. Turnage,…