In the Interest of B.C.A., a Child

Summary

The Texas Court of Appeals for the Seventh District affirmed an order terminating Father's parental rights to B.C.A. The court held, after independently reviewing the record in connection with appointed counsel's Anders brief, that sufficient evidence supported termination based on endangerment and that termination was in the child's best interest.

Holdings

1. After independently examining the entire record and the Anders brief, the court found no plausible or nonfrivolous ground for reversal.
2. Clear and convincing evidence supported termination under subsection (E) because Father’s methamphetamine use and unwillingness to seek treatment demonstrated conduct endangering B.C.A.’s physical or emotional well-being.
3. The evidence supported the trial court’s finding that termination of Father’s parental rights was in B.C.A.’s best interest.

Questions Presented

1. Whether the record presented any nonfrivolous or arguably reversible issue in Father’s Anders appeal from the termination of his parental rights.
2. Whether clear and convincing evidence supported termination under Texas Family Code section 161.001(b)(1)(E), based on conduct endangering the child’s physical or emotional well-being.
3. Whether the evidence supported the finding that termination of Father’s parental rights was in B.C.A.’s best interest.

Disposition

affirmed