In the Interest of A.H. and B.H., Children v. the State of Texas

CourtCourt of Appeals of Texas
DecidedDecember 11, 2025
Docket02-25-00373-CV
StatusPublished

This text of In the Interest of A.H. and B.H., Children v. the State of Texas (In the Interest of A.H. and B.H., 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.H. and B.H., Children v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-25-00373-CV ___________________________

IN THE INTEREST OF A.H. AND B.H., CHILDREN

On Appeal from the 442nd District Court Denton County, Texas Trial Court No. 24-0897-158

Before Kerr, Birdwell, and Bassel, JJ. Memorandum Opinion by Justice Birdwell MEMORANDUM OPINION

After a jury trial, the trial court terminated Mother’s parental rights to her

daughters Ann and Betty. 1 The jury found that the Texas Department of Family and 0

Protective Services (the Department) had proven that termination was in the

children’s best interest, see Tex. Fam. Code Ann. § 161.002(b)(2), and that Mother had

engaged in conduct specified in Subsections (D), (E), (N), and (O) of Section

161.001(b)(1) of the Texas Family Code, id. § 161.002(b)(1)(D), (E), (N), (O). 2

On appeal, Mother raises three issues: (1) the termination proceedings violated

her due-process rights because she did not understand them; (2) legally and factually

insufficient evidence supports the grounds found by the jury; and (3) trial counsel

rendered ineffective assistance.

We hold that Mother failed to preserve her due-process complaint, that the

evidence is legally and factually sufficient to support the jury’s finding on the

Subsection (E) ground (that Mother had engaged in conduct or knowingly placed the

children with persons who had engaged in conduct that endangered their physical or

emotional well-being), and that Mother has not shown that her trial counsel rendered

1 To protect the children’s identities, we use aliases when referring to them and refer to their family members by their relationship to the children. See Tex. Fam. Code Ann. § 109.002(d); Tex. R. App. P. 9.8(b)(2). 2 For purposes of this opinion, we focus only on the Subsection (E) ground— the finding that Mother had engaged in conduct or knowingly placed the children with persons who had engaged in conduct that endangered their physical or emotional well-being. See id. § 161.001(b)(1)(E).

2 ineffective assistance. Because we have found the evidence legally and factually

sufficient under the Subsection (E) ground and because only one ground is necessary

to support a termination, we need not determine whether sufficient evidence supports

the jury’s findings under Subsections (D), (N), and (O). In re J.F.G., III, 500 S.W.3d

554, 559 (Tex. App.—Texarkana 2016, no pet.). Accordingly, we overrule Mother’s

three issues and affirm the trial court’s judgment.

I. Background

This case started on January 29, 2024, when a neighbor found two-year-old

Betty in the street unattended. The neighbor went to Mother’s house and knocked on

the door, which came open. The neighbor shouted for someone, but no one

answered, so she called the police.

Shortly after the police arrived, Mother walked up to a number of people

standing across the street from her home; the neighbor, who was holding Betty, was

among this group. When the police determined that Mother was Betty’s parent,

Mother left the group and walked into her house, leaving Betty with the neighbor.

While walking to her house, Mother told the responding officer that she had a CPS 3 2

case that had been going on for ten years.

Once inside the house, the officer heard a noise upstairs and asked Mother to

identify who else was with them in the house. Mother said it was her six-year-old

3 CPS refers to Child Protective Services.

3 daughter, Ann. The officer asked Mother if she wanted to check on Ann, but Mother

declined.

Regarding why Mother had left her children alone, Mother said that she had

left to get diapers. She returned to her house, however, without diapers. 4 While one 3

officer talked to Mother, a second officer went upstairs and found about a dozen

diapers on the floor.

While talking with the officer, Mother stated that in addition to Ann and Betty,

she had three other children, and her CPS case involved these other three children.

Mother told the officer that she would resist anyone who tried to take Ann and Betty.

Mother also asserted that she had thought about killing herself.

Concerned about Mother’s behavior, the officers, among themselves,

questioned whether she was on methamphetamines or possibly bipolar. One officer

stated that he had looked for tracks on Mother’s arms but did not see any. The

officers wanted a medic to look at Mother and expressed concerns about a “med

clearance.” The medic, after seeing Mother, did not express any concerns. Although

4 One officer at the scene speculated that Mother had left the house to go “hooking.” One of Mother’s statements to the officers provided some basis for this speculation. At one point, Mother lamented that she had “banged this n****r for $15 for a f***ing box of diapers.”

4 not entirely clear, the officers appear to have tested something and to have concluded

that whatever it was that they tested was not the issue. 5 4

In addition to Mother’s behavior, the police were concerned about a number of

hazards within the home. For example, knives were left on the kitchen counter within

reach of the children, a bathtub was left half-filled with water, and a nugget of

marijuana was in a master closet within reach of the children. The officers arrested

Mother for abandoning and endangering a child with intent to return. Although the

officers took measures to screen the children from witnessing Mother’s arrest, the

children could hear Mother’s screams, and Ann became concerned: “Mom’s gonna

be in danger. I want my mom. She needs me. Those police are bad.” The officers

called CPS and kept Mother in a patrol car until a CPS investigator arrived at the

scene.

After the removal—from January 29, 2024, until trial in July 2025—Mother

had seventy-four opportunities to visit Ann and Betty. She visited them twice in

person and three times virtually. And despite being ordered from the outset to get a

psychological evaluation as part of her services, and despite acknowledging that she

could have done the evaluation virtually, Mother never got one.

When testifying, Mother denied using methamphetamines: “For the record, I 5

have never used meth.” Mother tested positive for marijuana in April 2024. Mother completed a drug and alcohol assessment on August 30, 2024, but did not follow the recommendations. After August 30, 2024, Mother did not take any drug tests. Mother refused to submit to drug tests fifteen times.

5 We will further develop the record as necessary to address Mother’s sufficiency

complaints.

II. Evidentiary Sufficiency

We address Mother’s legal and factual sufficiency challenges first. “Generally,

when a party presents multiple grounds for reversal of a judgment on appeal, the

appellate court should first address those points that would afford the party the

greatest relief.” Bradleys’ Elec., Inc. v. Cigna Lloyds Ins. Co., 995 S.W.2d 675, 677 (Tex.

1999). Legal sufficiency challenges generally afford the appellant the greatest relief.

In re Commitment of Jones, 650 S.W.3d 692, 698 (Tex.

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In the Interest of A.H. and B.H., Children v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-ah-and-bh-children-v-the-state-of-texas-texapp-2025.