In the Interest of J.D., a Child

Summary

The Texas Court of Appeals for the Seventh District affirmed the termination of Mother’s and Father’s parental rights to J.D. The court held that legally and factually sufficient evidence supported the statutory predicate grounds for termination and, as to Mother, the best-interest finding. The opinion discusses parental drug use, domestic violence, compliance with court-ordered services, endangerment, and the child’s need for a stable placement.

Holdings

1. The evidence was legally and factually sufficient to support findings that Mother knowingly placed or knowingly allowed J.D. to remain in conditions or surroundings that endangered her well-being and engaged in a course of conduct that endangered J.D.'s physical or emotional well-being.
2. The evidence was legally and factually sufficient to establish that termination of Mother's parental rights was in J.D.'s best interest.
3. The evidence was legally and factually sufficient to support a finding that Father engaged in a voluntary, deliberate, and conscious course of conduct that endangered J.D.'s physical or emotional well-being.
4. The court did not need to address Father's challenges to the findings under section 161.001(b)(1)(B), (C), (N), and (O) because the subsection (E) finding was sufficient, and Father did not challenge the best-interest finding.

Questions Presented

1. 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).
2. Whether legally and factually sufficient evidence supported the finding that termination of Mother's parental rights was in J.D.'s best interest.
3. Whether legally and factually sufficient evidence supported termination of Father's parental rights under section 161.001(b)(1)(E).
4. Whether the court needed to address Father's challenges to the remaining predicate grounds after affirming the subsection (E) finding.

Disposition

affirmed