In the Interest of A.S.-V.M., a Child v. the State of Texas

CourtCourt of Appeals of Texas
DecidedMarch 28, 2024
Docket10-23-00296-CV
StatusPublished

This text of In the Interest of A.S.-V.M., a Child v. the State of Texas (In the Interest of A.S.-V.M., 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.S.-V.M., a Child v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

IN THE TENTH COURT OF APPEALS

No. 10-23-00296-CV

IN THE INTEREST OF A.S.-V.M., A CHILD,

From the 82nd District Court Robertson County, Texas Trial Court No. 22-04-21441-CV

MEMORANDUM OPINION

Mother and Father appeal the trial court’s order terminating their parental rights

to A.S.-V.M. Both parents challenge the legal and factual sufficiency of the evidence to

support the finding that termination of their parental rights was in the child’s best

interest.1 We affirm the judgment of the trial court.

1 In a footnote, Mother makes the conclusory statement that she “disputes that the evidence is legally or factually sufficient to support a finding under [Texas Family Code Sections 161.001(b)(1)(D) and (b)(1)(E)]...” See TEX. FAM. CODE ANN. §§ 161.001(b)(1)(D), (b)(1)(E). She briefly explains that she does not raise sufficiency challenges to Grounds D and E as issues on appeal because only one predicate ground is required to support termination, and she concedes that the evidence is sufficient to support termination of her parental rights under Section 161.001(b)(1)(O). See Id. § 161.001(b)(1)(O). We note that the Texas Supreme Court has held that due process demands that we review the evidence supporting the findings underlying Grounds D or E when they are challenged on appeal even if we were to find that the evidence to support one of the other statutory grounds for termination was sufficient. Interest of N.G., 577 S.W.3d 230 (Tex. 2019). However, the ruling in N.G. mandates review of the sufficiency of the evidence underlying Background

The Texas Department of Family and Protective Services (“the Department”)

received a report that A.S.-V.M. was present in her home when one person threw bleach

in another person’s face. Mother and A.S.-V.M. lived in the home with several other

individuals. Father did not live in the home and was incarcerated at the time of the

incident. During its investigation, the Department learned that Mother was currently on

probation for a felony drug offense. At the suggestion of her probation officer, Mother

was scheduled to check into an inpatient drug rehab facility to address her marijuana use.

Because Mother believed that the rehab facility would not accept her for inpatient

treatment based solely on marijuana use, she told the Department that she planned to use

methamphetamine the next day, prior to checking into the facility, to ensure her

admittance.

The Department took emergency custody of A.S.-V.M. and filed a petition to

terminate Mother and Father’s parental rights. After a bench trial, the trial court

terminated Mother’s parental rights under Texas Family Code Sections 161.001(b)(1)(D),

(b)(1)(E), and (b)(1)(O), terminated Father’s parental rights under Texas Family Code

Grounds D and E only “[w]hen a parent has presented the issue on appeal.” Id. at 235. Mother specifically chose not to present the issue of sufficiency of the evidence supporting Grounds D and E, though her reasoning behind her decision is incorrect. Further, her footnote contains no substantive analysis, citations to the record, or supporting legal authority. See TEX. R. APP. P. 38.1(i). We “know of no authority obligating us to become advocates for a particular litigant through performing their research and developing their argument for them,” and we will not entertain issues that are inadequately briefed. See Id.; Tello v. Bank One, N.A., 218 S.W.3d 109,116 (Tex. App.—Houston [14th Dist. 2007, no pet.); see also Fredonia State Bank v. Gen. Am. Life Ins. Co., 881 S.W.2d 279, 283-84 (Tex. 1994).

In the Interest of A.S.-V.M., a Child Page 2 Sections 161.001(b)(1)(D), (b)(1)(E), and (b)(1)(Q), and found that termination of Mother

and Father’s parental rights was in the best interest of A.S.-V.M. See TEX. FAM. CODE ANN.

§§ 161.001(b)(1)(D), (b)(1)(E), (b)(1)(O), (b)(1)(Q), (b)(2). Mother and Father timely filed

separate notices of appeal, and the trial court filed findings of fact and conclusions of law.

STANDARD OF REVIEW

In conducting a legal sufficiency review in a parental termination case:

[A] court should look at all the evidence in the light most favorable to the finding to determine whether a reasonable trier of fact could have formed a firm belief or conviction that its finding was true. To give appropriate deference to the factfinder’s conclusions and the role of a court conducting a legal sufficiency review, looking at the evidence in the light most favorable to the judgment means that a reviewing court must assume that the factfinder resolved disputed facts in favor of its finding if a reasonable factfinder could do so. A corollary to this requirement is that a court should disregard all evidence that a reasonable factfinder could have disbelieved or found to have been incredible. This does not mean that a court must disregard all evidence that does not support the finding. Disregarding undisputed facts that do not support the finding could skew the analysis of whether there is clear and convincing evidence.

In re J.P.B., 180 S.W.3d 570, 573 (Tex. 2005) (per curiam) (quoting In re J.F.C., 96 S.W.3d

256, 266 (Tex. 2002)) (emphasis in original).

In a factual sufficiency review, a court of appeals must give due consideration to

evidence that the factfinder could reasonably have found to be clear and convincing. Id.

[T]he inquiry must be “whether the evidence is such that a factfinder could reasonably form a firm belief or conviction about the truth of the State's allegations.” A court of appeals should consider whether disputed evidence is such that a reasonable factfinder could not have resolved that

In the Interest of A.S.-V.M., a Child Page 3 disputed evidence in favor of its finding. If, in light of the entire record, the disputed evidence that a reasonable factfinder could not have credited in favor of the finding is so significant that a factfinder could not reasonably have formed a firm belief or conviction, then the evidence is factually insufficient.

Id. (footnotes and citations omitted); see In re C.H., 89 S.W.3d 17, 25 (Tex. 2002).

APPLICABLE LAW

There is a strong presumption that a child's best interests are served by

maintaining the parent-child relationship. Jordan v. Dossey, 325 S.W.3d 700, 729 (Tex.

App.—Houston [1st Dist.] 2010, pet. denied). However, while parental rights are of

constitutional magnitude, they are not absolute. Id. The non-exhaustive list of factors

that have been consistently considered in determining the best interest of the child were

set out in the Texas Supreme Court’s opinion, Holley v. Adams, 544 S.W.2d 367, 371-72

(Tex. 1976). These factors are: (1) the child's wishes; (2) the child’s emotional or physical

needs now and in the future; (3) the emotional or physical danger to the child now and

in the future; (4) the parenting abilities of the parties seeking custody; (5) programs

available to help those parties; (6) plans for the child by the parties seeking custody; (7)

the stability of the proposed placement; (8) the acts or omissions of the parent that

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Related

Holley v. Adams
544 S.W.2d 367 (Texas Supreme Court, 1976)
Fredonia State Bank v. General American Life Insurance Co.
881 S.W.2d 279 (Texas Supreme Court, 1994)
Jordan v. Dossey
325 S.W.3d 700 (Court of Appeals of Texas, 2010)
Tello v. Bank One, N.A.
218 S.W.3d 109 (Court of Appeals of Texas, 2007)
in the Interest of B. C. S., a Child
479 S.W.3d 918 (Court of Appeals of Texas, 2015)
in the Interest of J.P.B., a Child
180 S.W.3d 570 (Texas Supreme Court, 2005)
in the Interest of M.C.T., a Child
250 S.W.3d 161 (Court of Appeals of Texas, 2008)
in the Interest of S.N., a Child
272 S.W.3d 45 (Court of Appeals of Texas, 2008)
in the Interest of M.G.D. and B.L.D
108 S.W.3d 508 (Court of Appeals of Texas, 2003)
in the Interest of J.D., a Child
436 S.W.3d 105 (Court of Appeals of Texas, 2014)
in the Interest of S.L., a Child
421 S.W.3d 34 (Court of Appeals of Texas, 2013)
T. W. v. Texas Department of Family and Protective Services
431 S.W.3d 645 (Court of Appeals of Texas, 2014)
in the Interest of C.J.O., a Child
325 S.W.3d 261 (Court of Appeals of Texas, 2010)
in the Interest of D.S., N.S., Children
333 S.W.3d 379 (Court of Appeals of Texas, 2011)
in the Interest of A.C., a Child
394 S.W.3d 633 (Court of Appeals of Texas, 2012)
in Re Interest of N.G., a Child
577 S.W.3d 230 (Texas Supreme Court, 2019)
In the Interest of D.M.
58 S.W.3d 801 (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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