In the Interest of E.G., a Child

Summary

The Texas Seventh Court of Appeals reviewed an accelerated appeal from the termination of Mother’s and Father’s parental rights to E.G. The parents challenged the scope of de novo review, and Mother also challenged the sufficiency of the evidence supporting statutory predicate grounds and the child’s best interest. The court affirmed the trial court’s judgment terminating both parents’ rights.

Holdings

1. The referring trial court did not exceed the scope of de novo review because the intervenors timely requested a de novo hearing and specifically identified termination of Mother’s and Father’s parental rights, conservatorship, and related issues for presentation to the referring court.
2. Legally and factually sufficient evidence supported the trial court’s findings that Mother knowingly placed or knowingly allowed E.G. to remain in conditions or surroundings that endangered E.G.’s physical or emotional well-being and engaged in conduct or knowingly placed E.G. with persons whose conduct endangered E.G.’s physical or emotional well-being.
3. Legally and factually sufficient evidence supported the finding that termination of Mother’s parental rights was in E.G.’s best interest.

Questions Presented

1. Whether the referring trial court exceeded the scope of de novo review by considering termination of parental rights when the associate judge had ordered a monitored return.
2. Whether legally and factually sufficient evidence supported termination of Mother’s parental rights under Texas Family Code section 161.001(b)(1)(D) and (E).
3. Whether legally and factually sufficient evidence supported the finding that termination of Mother’s parental rights was in E.G.’s best interest.

Disposition

affirmed