In the Interest of A.J.C., a Child v. the State of Texas

CourtCourt of Appeals of Texas
DecidedMarch 12, 2025
Docket07-24-00331-CV
StatusPublished

This text of In the Interest of A.J.C., a Child v. the State of Texas (In the Interest of A.J.C., a Child 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.J.C., a Child v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-24-00331-CV

IN THE INTEREST OF A.J.C., A CHILD

On Appeal from the County Court at Law No. 1 Randall County, Texas Trial Court No. 80487-L1, Honorable Abe Lopez, Presiding by Assignment

March 12, 2025 MEMORANDUM OPINION Before QUINN, C.J., and PARKER and DOSS, JJ.

The mother of AJC appeals from a judgment that terminated her rights to her child.

Apparently, this was the second of two efforts. The first resulted in an April 2023 final

order terminating father’s parental rights and designating mother as possessory

conservator of AJC. Termination efforts began anew once mother subsequently tested

positive for methamphetamine.

Through two issues, mother complains that certain evidence should not have been

admitted and that the evidence was legally and factually insufficient for the trial court to

have found that termination of her parental rights was in the best interest of the child. We

affirm. Background

Mother first used methamphetamine in 2015. She began using again in 2018 to

help her function after her husband committed suicide. She continued to use when she

met another man and became pregnant. She used until she was about twenty weeks

along. At some point, she said the father of that child shoved methamphetamine in her

mouth, and, as a consequence, according to mother, she and that baby tested positive

for methamphetamine at the time of that child’s birth a few weeks later.

In 2019, mother was convicted of assault family violence after an altercation with

her then-partner. The Texas Department of Family and Protective Services (Department)

opened a case involving mother in 2020. Mother did not complete her services in that

case. Furthermore, the child was placed with the father, while mother was denied access

or contact.

Mother later conceived the child at issue here, AJC, by another man. AJC was

born in March 2021 and removed from mother’s care in September 2021 due to concerns

of domestic violence and drug use in the home. The Department initially petitioned to

terminate mother’s parental rights to AJC. In the interim, mother was given a service plan

that set forth tasks and services she was required to perform to secure the return of AJC.

Mother completed many of the services but continued to struggle with sobriety and the

maintenance of a stable life. As mentioned above, that petition for termination resulted

in the designation of mother as possessory conservator in April 2023. Yet, after a positive

drug screen in December 2023, the Department petitioned to terminate once again. A

hearing was held on that matter in September 2024.

At the hearing, the court heard evidence pertaining to the predicate grounds for

termination and to AJC’s best interests. Thereafter, the court terminated mother’s rights 2 to AJC under section 161.001(b)(1)(D), (E), and (O) of the Family Code and determined

termination was in AJC’s best interest under section 161.001(b)(2).

Issue One—Admission of Drug Screens

Through her first issue, mother argues the trial court erred in admitting the results

of drug screens taken of herself and AJC. Allegedly, the results were hearsay due to

deficient authentication as business records. So too were they untrustworthy, in her view.

We overrule the issue.

Regarding the test pertaining to AJC, mother did object. After the court overruled

same, the document and test results were the source of further questioning. Mother failed

to object to those additional questions and answers. Nor had she sought a running

objection when the court admitted the evidence over her objection. Having failed to either

continue objecting or secure a running objection, mother failed to preserve for review her

complaint encompassing the test results showing that AJC tested positive for

methamphetamine. Bay Area Healthcare Group, Ltd. v. McShane, 239 S.W.3d 231, 235-

36 (Tex. 2007) (holding that purported error in the admission of evidence was waived

when objection was not made to ensuing questions and complainant failed to request

running objection); In re Commitment of Massingill, No. 09-15-00365-CV, 2016 Tex. App.

LEXIS 4769, at *10 (Tex. App.—Beaumont May 5, 2016, pet. denied) (mem. op.) (stating

that to preserve error regarding the admission of evidence, the complaining party must

timely and specifically object each time it is offered or obtain a running objection).

As for the documents showing mother’s testing positive for methamphetamine, like

evidence was admitted from other sources (including mother’s own concession) without

objection. That being so, any error in admitting the records of her drug screens was

harmless. See In re L.T., No. 07-09-0280-CV, 2010 Tex. App. LEXIS 2250, at *10-11 3 (Tex. App.—Amarillo Mar. 30, 2010, no pet.) (mem. op.) (holding that error in admission

of evidence is harmless when like evidence is admitted elsewhere without objection).

Issue Two—Sufficiency of Evidence to Support Best-Interest Finding By her second issue, mother argues the evidence was insufficient to support the

trial court’s best-interest finding. We overrule the issue.

The standard of review is that described in In re A.C., 560 S.W.3d 624 (Tex. 2018).

We apply it here.

Next, in determining the best interests of a child, a variety of factors have been

consistently considered. They were itemized in Holley v. Adams, 544 S.W.2d 367 (Tex.

1976). The itemization is not exhaustive, but simply lists circumstances that have been

or could be pertinent to the determination. Id. Not all must be established, and the

absence of some does not preclude a factfinder from reasonably forming a strong

conviction that termination is in the child’s best interest. See In re C.H., 89 S.W.3d 17,

27 (Tex. 2002). Furthermore, evidence relating to the predicate statutory grounds for

termination under section 161.001(b)(1) also may be probative to the analysis. Id. at 27-

28. And, to that end, the failure to challenge the predicate grounds found by the court is

a tacit concession by the parent that the evidence establishing those grounds is sufficient.

In re T.C., Nos. 07-18-00080-CV, 07-18-00081-CV, 2018 Tex. App. LEXIS 6769, at *13

(Tex. App.—Amarillo Aug. 23, 2018, pet. denied) (mem. op.). That said, we turn to the

record before us.

Mother had a lengthy history of drug use commencing in 2015. It included the

ingestion of methamphetamine when pregnant and while caring for her children.

Moreover, AJC tested positive for methamphetamine at the young age of six months.

4 Though the habit waned for a time, mother nevertheless tested positive for

methamphetamine shortly before the final hearing.

So too was there a history of domestic violence wherein she was both the victim

and aggressor. Evidence of domestic violence is a consideration in the Holley analysis,

see In re J.I.T.P., 99 S.W.3d 841, 846 (Tex. App.—Houston [14th Dist.] 2003, no pet.), as

is parental drug abuse.

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Related

Holley v. Adams
544 S.W.2d 367 (Texas Supreme Court, 1976)
Bay Area Healthcare Group, Ltd. v. McShane
239 S.W.3d 231 (Texas Supreme Court, 2007)
In the Interest of J.I.T.P.
99 S.W.3d 841 (Court of Appeals of Texas, 2003)
in the Interest of A.C., a Child
394 S.W.3d 633 (Court of Appeals of Texas, 2012)
In the interest of C.H.
89 S.W.3d 17 (Texas Supreme Court, 2002)

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