C. Q. v. Texas Department of Family and Protective Services

Summary

The Texas Court of Appeals, Third District, affirmed an order terminating C.Q.’s parental rights to her child. The court held that the Texas Department of Family and Protective Services made reasonable reunification efforts and that the evidence was legally and factually sufficient to support termination under Texas Family Code section 161.001(b)(1)(D) and (E), as well as the child’s best interest. The court also concluded that the trial court’s written findings sufficiently described the Department’s reunification efforts.

Holdings

1. The evidence was legally and factually sufficient to support the finding that the Department made reasonable efforts to return Eva to Mother, and the termination order described those efforts with sufficient specificity. The conflicting drug-test results did not negate the Department's other undisputed reunification efforts.
2. Legally and factually sufficient evidence supported termination under Texas Family Code section 161.001(b)(1)(D) and (E).
3. Legally and factually sufficient evidence supported the trial court's finding that termination of Mother's parental rights was in Eva's best interest.

Questions Presented

1. Whether legally and factually sufficient evidence supported the finding that the Department made reasonable efforts to reunify Mother and Eva and whether the termination order described those efforts with sufficient specificity.
2. Whether legally and factually sufficient evidence supported termination under Texas Family Code section 161.001(b)(1)(D) and (E).
3. Whether legally and factually sufficient evidence supported the finding that termination was in Eva's best interest.

Disposition

affirmed