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In the Interest of P.H.S. and E.K.S., Children v. the State of Texas2026-06-24
…ironment, we consider the factors set forth in section 263.307(b) of the Texas Family Code. 4 See id. § 263.307(b). We also consider the Holley factors. 5 See Holley v. Adams, 544 S.W.2d 367, 371–72 (Tex. 1976). These factors are not exhaustive. In re C.H., 89 S.W.3d 17, 27 (Tex. 2002). “The absence of evidence about some of these considerations would not preclude a factfinder from reasonably forming a strong conviction or belief that termination is in the child’s best interest, particularly if the evidence were undisputed that the parental relationship endangered the safety of the child.” Id. In analyzing…
In the Interest of A.D., S.R., and K.A., Children v. the State of Texas2026-06-18
The citing opinion is in this library and the link is real, but the passage could not be quoted: this decision is named there in a short form, in a parallel reporter, or in text that came through OCR imperfectly. Recorded as unquoted rather than dropped.
In the Interest of J.C.B.G., Children v. the State of Texas2026-06-17
…19 S.W.3d 615, 620 (Tex. App.—San Antonio 2013, pet. denied). Conduct supporting a statutory ground for termination is probative of best interest, and the factfinder may measure a parent’s future ability to meet a child’s needs by past conduct. In re C.H., 89 S.W.3d 17, 28 Tex. (2002); E.D., 419 S.W.3d at 620. Ultimately, the focus must remain on the child’s best interest, not the interest of the parent. In re J.E.F., No. 04-26-00086-CV, 2026 WL 1326514, at *5 (Tex. App.—San Antonio May 13, 2026, no pet. h.) (mem. op.) (citing Dupree v. Tex. Dep’t of Protective & Regulatory Servs., 907 S.W.2d 81, 86 (Tex. A…
In the Interest of I.G., a Child v. the State of Texas2026-06-16
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In the Interest of A.A. a Child v. Department of Family and Protective Services2026-06-11
…ights is in the child’s best interest. Id. Moreover, evidence supporting termination under one of the grounds listed in section 161.001(b)(1) can also be considered in support of a finding that termination is the best interest of the child. See In re C.H., 89 S.W.3d 17, 28 (Tex. 2002) (holding same evidence may be probative of both section 161.001(b)(1) grounds and best-interest finding). In addition, the Texas Family Code sets out factors to be considered in evaluating the parent’s willingness and ability to provide the child with a safe environment, including: the child’s age and physical and ment…
In the Interest of M.S., M.J.S., and N.E.S., Children v. the State of Texas2026-06-10
…04-25-00782-CV See id. § 263.307(b). We also consider the Holley factors. 6 See Holley v. Adams, 544 S.W.2d 367, 371–72 (Tex. 1976). These factors are not exhaustive. In re C.H., 89 S.W.3d 17, 27 (Tex. 2002). “The absence of evidence about some of these considerations would not preclude a factfinder from reasonably forming a strong conviction or belief that termination is in the child’s best interest, particularly if the evidence were undisputed that the parental relationship endangered the safety of the child.” Id. In analyzing…
In the Interest of K.N., K.L., K.L., and K.L., Children2026-06-05
…er’s role.” 15 In its review, the Court disregards evidence that Father contributed to the abuse in the home. Further, it isolates other evidence 11 In re E.C.R., 402 S.W.3d 239, 240 (Tex. 2013) (alteration in original) (quoting In re C.H., 89 S.W.3d 17, 26 (Tex. 2002)). 12 In re J.F.C., 96 S.W.3d 256, 265–66 (Tex. 2002). 13 In re J.F.-G., 627 S.W.3d 304, 311–12 (Tex. 2021). 14 J.W., 645 S.W.3d at 741 (quoting J.F.C., 96 S.W.3d at 266). 15 In re A.C., 560 S.W.3d 624, 630 (Tex. 2018). 6 supporting termination as t…
In the Interest of P.A., Jr., L.L.-A., and S.A., Children v. the State of Texas2026-06-05
…t a factfinder could reasonably form a firm belief or conviction about the truth of the State’s allegations.” In re A.C., No. 06-25-00084-CV, 2026 WL 878798, at *2 (Tex. App.— Texarkana 2026, no pet.) (mem. op.) (alteration in original) (quoting In re C.H., 89 S.W.3d 17, 25 (Tex. 2002)). “Both legal and factual sufficiency review deal with whether ‘a reasonable factfinder could form a firm belief or conviction,’ but there is a difference between legal and factual sufficiency.” Id. (quoting In re A.C., 560 S.W.3d at 631). For legal sufficiency, “we consider all the evidence in the light most favorable…
In the Interest of H.S., B.S., and M.S., Children2026-06-05
…ul implications on appeal. “As a 17 matter of logic, a finding that must be based on clear and convincing evidence cannot be viewed on appeal the same as one that may be sustained on a mere preponderance.” In re C.H., 89 S.W.3d 17, 25 (Tex. 2002). Accordingly, we have instructed the courts of appeals on the enhanced nature of factual-sufficiency review in parental-termination cases. See id. at 25–26; see also, e.g., In re A.B., 437 S.W.3d 498, 502–03 (Tex. 2014). We do not today address those standards, or whether the court of appeals complied with them, because we conclu…
In the Interest of B.A. and B.A., Children v. the State of Texas2026-06-04
…ould reasonably form a firm conviction or belief that the Department proved the termination ground and that termination would be in the child’s best interest. In re A.B., 437 S.W.3d 498, 500, 502–03 (Tex. 2014); see Tex. Fam. Code § 161.001(b); In re C.H., 89 S.W.3d 17, 28 (Tex. 2002). If the factfinder reasonably could form such a firm conviction or belief, then the evidence is factually sufficient. C.H., 89 S.W.3d at 18–19. But if a factfinder reasonably could not—because the disputed evidence that could not reasonably support the finding is too significant—then the evidence is factually insufficient. In…
Brennan Short v. Jamie Short2026-06-03
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In the Interest of J.J. III and D.R.L.J., Children v. the State of Texas2026-06-03
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In the Interest of P.M.B., J.Q.B., M.B. AKA Baby Girl B., K.L.B. AKA K.L.B., Children v. Department of Family and Protective Services2026-05-28
…e child’s best interests. Id. 7 Because the burden of proof in termination proceedings is clear and convincing evidence, a heightened standard of review in an evidentiary challenge is required. In re C.H., 89 S.W.3d 17, 25 (Tex. 2002). Thus, under either legal sufficiency or factual sufficiency review, we determine whether the evidence is such that a trier of fact could have reasonably formed a firm belief or conviction that its finding was true. Id.; In re J.W., 645 S.W.3d 726, 741 (Tex. 2022). The “distinction between legal and factual sufficiency lies i…
In the Interest of J.S.C. and J.M.C., Children v. the State of Texas2026-05-21
…dards of review for legal and factual sufficiency of the evidence in cases involving the termination of parental rights are well established and will not be repeated here. See In re J.F.C., 96 S.W.3d 256, 264–68 (Tex. 2002) (legal sufficiency); In re C.H., 89 S.W.3d 17, 25 (Tex. 2002) (factual sufficiency). In a bench trial, the trial court, as factfinder, is the sole judge of the witnesses’ credibility and demeanor. In re J.O.A., 283 S.W.3d 336, 346 (Tex. 2009). In a proceeding to terminate the parent-child relationship brought under section 161.001 of the Family Code, the Department of Family and…
In the Interest of D.W., A.W., B.S.D, and T.G., Children v. the State of Texas2026-05-21
The citing opinion is in this library and the link is real, but the passage could not be quoted: this decision is named there in a short form, in a parallel reporter, or in text that came through OCR imperfectly. Recorded as unquoted rather than dropped.
In the Interest of R.G., III, a Child v. the State of Texas2026-05-21
…wn. In re H.R.M., 209 S.W.3d 105, 108 (Tex. 2006). We review the whole record to decide whether a factfinder could reasonably form a firm conviction or belief that the Department proved the grounds for termination. Tex. Fam. Code § 161.001(b); In re C.H., 89 S.W.3d 17, 28 (Tex. 2002). If the factfinder reasonably could form such a 14 firm conviction or belief, then the evidence is factually sufficient. C.H., 89 S.W.3d at 18–19. 3. Standard for Termination of a Parent–Child Relationship In part of his first issue, Father argues that termination…
In the Interest of Z.S., Z.S., M.S. III, Children v. the State of Texas2026-05-21
…olute. Just as it is imperative for courts to recognize the constitutional underpinnings of the parent-child relationship, it is also essential that emotional and physical interests of the child not be sacrificed merely to preserve that right.” In re C.H., 89 S.W.3d 17, 26 (Tex. 2002). Striking that balance, a trial court may terminate a parent-child relationship, pursuant to Texas Family Code section 161.001, only if it finds by clear and convincing evidence one predicate ground enumerated in subsection (b)(1) and that termination is in the child’s best interest. TEX. FAM. CODE § 161.001(b)(1)–(2). Clear…
In the Interest of G.S.S. and S.D.S., Children v. the State of Texas2026-05-14
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In the Interest of J.E.F. and J.J.F., Children v. the State of Texas2026-05-13
…t interest[.]” In re J.B.-F., No. 04-18-00181-CV, 2018 WL 3551208, at *3 (Tex. App.—San Antonio July 25, 2018, pet. denied) (mem. op.). Evidence that proves a statutory ground for termination may also be probative on the issue of best interest. In re C.H., 89 S.W.3d 17, 28 (Tex. 2002). “A trier of fact may measure a parent’s future conduct by his 3 The statutory factors include: “(1) the child’s age and physical and mental vulnerabilities; (2) the frequency and nature of out-of-home placements; (3) the magnitude, frequency, and circumstances of the harm to the child; (4) whether the child has been the vict…
In the Interest of D.J., a Child v. the State of Texas2026-04-30
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In the Interest of A.C. and N.C., Children v. the State of Texas2026-04-30
…of the termination grounds may also be probative of best interest. In re A.C., 560 S.W.3d 624, 631–32 (Tex. 2018). The Department need not present evidence of each Holley factor; in some circumstances, evidence of only one may be sufficient. In re C.H., 89 S.W.3d 17, 27 (Tex. 2002). As he did in his second issue, Appellant argues that the absence of physical injuries to the children undermines the trial court’s best-interest finding. He also contends that the lack of evidence showing the children feared him, or that he had abandoned them, cuts against best interest. Finally, he argues that th…
In the Interest of K.L.G., K.L.G., K.A.R.G., K.L.G., Children v. the State of Texas2026-04-30
…lity of the witnesses “so long as those determinations are not themselves unreasonable.” In re J.P.B., 180 S.W.3d 12 at 573; see In re H.R.M., 209 S.W.3d 105, 108 (Tex. 2006) (per curiam); see also In re C.H., 89 S.W.3d 17, 26 (Tex. 2002) (“A standard that focuses on whether a reasonable jury could form a firm conviction or belief retains the deference an appellate court must have for the factfinder’s role.”). “In a bench trial, the trial court acts as the fact-finder and is the sole judge of witness credibility.” In re A.M., 418 S.W.3d 830, 841 (Tex. App.— Da…
In the Interest of C.F., a Child v. the State of Texas2026-04-30
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In the Interest of E.T., E.T., E.T., E.D., Children v. the State of Texas2026-04-30
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In the Interest of A.M., a Child v. the State of Texas2026-04-30
…solute. Just as it is imperative for courts to recognize the constitutional underpinnings of the parent-child relationship, it is also essential that emotional and physical interests of the child not be sacrificed merely to preserve that right.” In re C.H., 89 S.W.3d 17, 26 (Tex. 2002). “The State’s fundamental interest in parental-rights termination cases is to protect the best interest of the child.” In re M.S., 115 S.W.3d 534, 548 (Tex. 2003). “The interests of the child and the State are typically expressed as being an inherent part of the analysis of the parent’s rights.” In re C.C., 720 S.W.3d…
In the Interest of E.M.M Jr., N.M.M., N.J.M., I.A.M., M.S.R., A.L.M., Children v. the State of Texas2026-04-29
The citing opinion is in this library and the link is real, but the passage could not be quoted: this decision is named there in a short form, in a parallel reporter, or in text that came through OCR imperfectly. Recorded as unquoted rather than dropped.