In the Interest of Z.A.A., a Child

Summary

The Texas Court of Appeals for the First District considered an accelerated appeal from an order terminating a father’s parental rights to Z.A.A. The court held that legally and factually sufficient evidence supported findings that the Department of Family and Protective Services made reasonable efforts to reunify the child with the father and that termination was in the child’s best interest. The court affirmed the trial court’s order.

Holdings

1. The evidence was legally and factually sufficient to support the finding that DFPS made reasonable efforts to return Z.A.A. to father. An implemented family service plan is generally evidence of reasonable efforts, but it is not the exclusive means of proving that element; the governing inquiry is whether DFPS made reasonable, rather than ideal, efforts.
2. The evidence was legally and factually sufficient to support the finding that termination of father's parental rights was in Z.A.A.'s best interest.

Questions Presented

1. Whether legally and factually sufficient evidence supported the finding under Texas Family Code section 161.001(b)(1)(N)(i) that DFPS made reasonable efforts to return Z.A.A. to father.
2. Whether legally and factually sufficient evidence supported the finding under Texas Family Code section 161.001(b)(2) that termination of father's parental rights was in Z.A.A.'s best interest.

Disposition

affirmed