In the Interest of A.A. Jr. and K.A., Children v. the State of Texas

CourtCourt of Appeals of Texas
DecidedAugust 8, 2024
Docket10-24-00084-CV
StatusPublished

This text of In the Interest of A.A. Jr. and K.A., Children v. the State of Texas (In the Interest of A.A. Jr. and K.A., Children v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Interest of A.A. Jr. and K.A., Children v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

IN THE TENTH COURT OF APPEALS

No. 10-24-00084-CV

IN THE INTEREST OF A.A., JR. AND K.A., CHILDREN

From the County Court at Law Hill County, Texas Trial Court No. CV328-22CCL

MEMORANDUM OPINION

The mother of A.A., Jr. and K.A. appeals a judgment that terminated her parental

rights to her children. 1 The mother complains that the evidence was legally insufficient

for the trial court to have found that she committed the predicate ground set forth in

Section 161.001(b)(1)(D) (endangering conditions) or that termination was in the best

interest of the children. See TEX. FAM. CODE §161.001(b)(1)(D), 161.001(b)(2). Because we

find no reversible error, we affirm the judgment of the trial court.

STANDARD OF REVIEW

The standard of review for legal sufficiency of the evidence in cases involving the

1 The father’s rights were also terminated, but he did not appeal the trial court’s judgment. termination of parental rights is well established and will not be repeated here. See In re

J.F.C., 96 S.W.3d 256, 264-68 (Tex. 2002). The trial court, as factfinder, is the sole judge of

the witnesses' credibility and demeanor. In re J.O.A., 283 S.W.3d 336, 346 (Tex. 2009).

Additionally, if the evidence is sufficient as to one predicate act, it is not necessary to

address the other predicate acts because sufficient evidence as to only one predicate act

in addition to the best interest finding is necessary to affirm a termination judgment. In

re N.G., 577 S.W.3d 230, 232-33 (Tex. 2019).

PREDICATE ACTS

In her first issue, the mother complains that the evidence was legally insufficient

for the trial court to have found that she committed the predicate ground in Section

161.001(b)(1)(D). The termination judgment reflects that the mother’s parental rights

were terminated based on three predicate grounds: endangering environment

(Subsection (D)); endangering conduct (Subsection (E)); and failure to comply with a

court-ordered service plan (Subsection (O)). See TEX. FAM. CODE § 161.001(b)(1)(D), (E),

& (O). The mother acknowledges in her brief that the evidence was legally sufficient as

to endangering conduct and the failure to complete her service plan. By failing to

challenge all of the trial court's predicate ground findings, the mother has waived any

complaint about the sufficiency of the evidence to support the judgment as to predicate

grounds. See In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam) (stating that "only

one ground is required to terminate parental rights"). Because the mother has not

challenged the sufficiency of the evidence as to Section 161.001(b)(1)(E) or (O), we find In the Interest of A.A. Jr. & K.A., Children Page 2 that there was sufficient evidence as to one ground to support the termination of her

parental rights.

Generally, we are required to address the sufficiency of the evidence as to

Subsection (D) or (E) due to potential collateral consequences in the future. See In re N.G.,

577 S.W.3d at 236‒37 ("allowing a challenged section 161.001(b)(1)(D) or (E) finding to

stand unreviewed...creates the risk that a parent will be automatically denied the right to

parent other children even if the evidence supporting the section 161.001(b)(1)(D) or (E)

finding were insufficient"). However, we are not required to address that complaint

because the unchallenged ground pursuant to Subsection (E) satisfies this requirement.

See id. We overrule issue one.

BEST INTEREST

In her second issue, the mother complains that the evidence was legally

insufficient for the trial court to have found that termination was in the best interest of

the children. In determining the best interest of a child, a number of factors have been

consistently considered which were set out in the Texas Supreme Court's opinion, Holley

v. Adams, 544 S.W.2d 367, 371-72 (Tex. 1976). This list is not exhaustive, but simply

identifies factors that have been or could be pertinent in the best interest determination.

Id. There is no requirement that all of these factors must be proved as a condition

precedent to parental termination, and the absence of evidence about some factors does

not preclude a factfinder from reasonably forming a strong conviction that termination is

in the children's best interest. See In re C.H., 89 S.W.3d 17, 27 (Tex. 2002). The Holley In the Interest of A.A. Jr. & K.A., Children Page 3 factors focus on the best interest of the children, not the best interest of the parent. Dupree

v. Tex. Dep't of Protective & Regulatory Servs., 907 S.W.2d 81, 86 (Tex. App.—Dallas 1995,

no writ). And while no one factor is controlling, the analysis of a single factor may be

adequate in a particular situation to support a finding that termination is in the children's

best interest. In re J.O.C., 47 S.W.3d 108, 115 (Tex. App.—Waco 2001, no pet). Evidence

relating to the predicate grounds under section 161.001(b)(1) also may be relevant to

determining the best interest of the children. See C.H., 89 S.W.3d at 27-28.

The children were removed from the mother and father due to an incident

involving domestic violence and alcohol in the presence of the children, who were almost

4 years old and 20 months old. The mother took a hair test during the investigation which

showed a high amount of alcohol. The caseworker testified that she was told that the

high number indicated excessive, chronic alcohol abuse. The mother and father had an

on-again, off-again relationship. The mother finally split from the father approximately

six months into the proceedings after an incident involving the father and the mother’s

boyfriend.

The mother participated in services and the children were returned to the mother

on a monitored return. The mother was residing with her father at that time, who was a

registered sex offender. The mother’s father had been convicted of sexually assaulting

the mother’s sister when she was a young teenager, although the mother did not believe

that her father was guilty. The mother informed the caseworker that she had concerns

about the father developing dementia. The department informed the mother that her In the Interest of A.A. Jr. & K.A., Children Page 4 father was not allowed to be a caregiver of the children by himself.

Ten days after the children were returned, the mother was arrested for driving

while intoxicated, with an alcohol concentration over .15. The children were in the care

of the mother’s father in violation of the department’s stipulation. The children were

removed from the mother again. The children told a caseworker that the mother and her

father would drink together every day.

The mother was required to participate in drug and alcohol testing throughout the

case, but many of the tests were either missed or diluted samples were given.

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Related

In Re J.O.A.
283 S.W.3d 336 (Texas Supreme Court, 2009)
Holley v. Adams
544 S.W.2d 367 (Texas Supreme Court, 1976)
Dupree v. Texas Department of Protective & Regulatory Services
907 S.W.2d 81 (Court of Appeals of Texas, 1995)
in the Interest of Z.M.M., a Child
577 S.W.3d 541 (Texas Supreme Court, 2019)
in Re Interest of N.G., a Child
577 S.W.3d 230 (Texas Supreme Court, 2019)
In the Interest of J.O.C.
47 S.W.3d 108 (Court of Appeals of Texas, 2001)
In the interest of C.H.
89 S.W.3d 17 (Texas Supreme Court, 2002)
In the Interest of J.F.C.
96 S.W.3d 256 (Texas Supreme Court, 2002)

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In the Interest of A.A. Jr. and K.A., Children v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-aa-jr-and-ka-children-v-the-state-of-texas-texapp-2024.