C. R. F. v. Texas Department of Family and Protective Services

Summary

The Texas Court of Appeals, Third District, reviews an order terminating C.R.F.’s parental rights to three children under Texas Family Code sections 161.001(b)(1)(D), (E), and (b)(2). The court addresses the sufficiency of the evidence concerning reasonable reunification efforts, statutory endangerment grounds, and the children’s best interests. The opinion states that the trial court’s termination order is affirmed.

Holdings

1. The evidence was legally sufficient to support the finding that the Department made reasonable efforts to return the children to Mother.
2. The evidence was legally and factually sufficient to establish that Mother knowingly placed the children in conditions or surroundings that endangered their physical or emotional well-being.
3. The evidence was legally and factually sufficient to support the finding that termination of Mother's parental rights was in the children's best interests.
4. After the termination order was upheld, Mother lacked standing to challenge the appointment of the Department as the children's permanent managing conservator.

Questions Presented

1. Whether legally and factually sufficient evidence supported the finding that the Department made reasonable efforts to reunify the children with Mother.
2. Whether legally and factually sufficient evidence supported termination under Texas Family Code section 161.001(b)(1)(D).
3. Whether legally and factually sufficient evidence supported the finding that termination was in the children's best interests.
4. Whether Mother had standing to challenge the appointment of the Department as the children's permanent managing conservator after her parental rights were terminated.

Disposition

affirmed