In the Interest of J.A.B., S.M.E., C.C.E., and M.B.E., Children

Summary

The Fourth Court of Appeals of San Antonio affirmed an order terminating the parental rights of Mother and Father C.J.E. Father challenged the sufficiency of the evidence supporting the statutory endangerment ground, and both parents challenged the best-interest findings. The court held that the evidence was legally and factually sufficient, including evidence of domestic violence, child abuse, substance abuse, instability, and the children’s placements.

Holdings

1. The evidence is legally and factually sufficient to support the trial court's subsection (E) finding. Father's history of domestic violence against Mother and the children, combined with his long history of methamphetamine abuse, established an endangering course of conduct.
2. The evidence is legally and factually sufficient to support the trial court's best-interest finding as to Father.
3. The evidence is legally and factually sufficient to support the trial court's best-interest finding as to Mother.

Questions Presented

1. Whether the evidence is legally and factually sufficient to support the trial court's finding under statutory ground (E) that Father engaged in conduct endangering the physical or emotional well-being of his children
2. Whether the evidence is legally and factually sufficient to support the finding that termination of Father's parental rights is in the children's best interests
3. Whether the evidence is legally and factually sufficient to support the finding that termination of Mother's parental rights is in the children's best interests

Disposition

affirmed