In the Interest of B.H., a Child v. the State of Texas

CourtTexas Court of Appeals, 4th District (San Antonio)
DecidedJanuary 21, 2026
Docket04-25-00494-CV
StatusPublished

This text of In the Interest of B.H., a Child v. the State of Texas (In the Interest of B.H., a Child v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 4th District (San Antonio) 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 B.H., a Child v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-25-00494-CV

IN THE INTEREST OF B.H., a Child

From the 438th Judicial District Court, Bexar County, Texas Trial Court No. 2024-PA-00827 Honorable Lisa Jarrett, Judge Presiding

Opinion by: Irene Rios, Justice

Sitting: Irene Rios, Justice Adrian A. Spears II, Justice Velia J. Meza, Justice

Delivered and Filed: January 21, 2026

AFFIRMED

Appellant Mother appeals the trial court’s order terminating her parental rights to her child,

B.H. 1 In her sole issue, Mother challenges the sufficiency of the evidence supporting the trial

court’s finding that termination was in B.H.’s best interest. We affirm.

BACKGROUND

The Department became involved in the underlying case when Mother and B.H. both tested

positive for methamphetamines and THC when B.H. was born. The Department initially offered

1 To protect the identity of minor children in an appeal from an order terminating parental rights, we refer to the parents as “Mother” and “Father,” and we refer to the child using his initials or as “the child.” See TEX. FAM. CODE ANN. § 109.002(d); TEX. R. APP. P. 9.8(b)(2). The trial court’s order also terminated Father’s parental rights to B.H.; however, Father does not appeal. 04-25-00494-CV

Mother family-based safety services (“FBS”) to avoid removal. When Mother failed to engage

with FBS, the Department sought removal of the child.

On May 21, 2024, the Department filed a petition seeking termination of Mother’s parental

rights. The trial court held a bench trial on May 12, 2025. The trial court heard testimony from

Shanice Morris, the Department’s removal investigator; Cynthia Cruz, the Department’s

caseworker; Rachel Halm, the Department’s family specialist that was assigned to assist B.H.’s

foster family; Mother; Father; and B.H.’s maternal grandfather.

On July 16, 2025, the trial court signed an order terminating Mother’s parental rights to

B.H. The trial court terminated Mother’s parental rights based on statutory grounds (D), (E), (N),

and (O) in subsection 161.001(b)(1) of the Texas Family Code. See TEX. FAM. CODE ANN.

§§ 161.001(b)(1)(D), (E), (N), (O). The trial court also found it was in the children’s best interests

to terminate Mother’s parental rights. See id. § 161.001(b)(2). Mother appeals.

STATUTORY REQUIREMENTS AND STANDARD OF REVIEW

To terminate parental rights pursuant to section 161.001 of the Texas Family Code, the

Department has the burden to prove by clear and convincing evidence: (1) one of the predicate

grounds in subsection 161.001(b)(1); and (2) that termination is in the best interest of the child.

TEX. FAM. CODE ANN. § 161.001(b). Clear and convincing evidence requires “proof that will

produce in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations

sought to be established.” Id. § 101.007.

When reviewing the sufficiency of the evidence, we apply well-established standards of

review. See id. §§ 101.007, 161.206(a); In re H.R.M., 209 S.W.3d 105, 108 (Tex. 2006)

(conducting a factual sufficiency review); In re J.P.B., 180 S.W.3d 570, 573 (Tex. 2005)

(conducting a legal sufficiency review).

-2- 04-25-00494-CV

“In reviewing the legal sufficiency of the evidence to support the termination of parental

rights, we must ‘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.’” In re J.L.B., No. 04-17-00364-CV, 2017 WL 4942855, at *2 (Tex. App.—San Antonio

Nov. 1, 2017, pet. denied) (mem. op.) (quoting In re J.F.C., 96 S.W.3d 256, 266 (Tex. 2002)).

“[A] reviewing court must assume that the factfinder resolved disputed facts in favor of its finding

if a reasonable factfinder could do so.” J.F.C., 96 S.W.3d at 266. “A corollary to this requirement

is that a [reviewing] court should disregard all evidence that a reasonable factfinder could have

disbelieved or found to have been incredible.” Id.

“In reviewing the factual sufficiency of the evidence to support the termination of parental

rights, we ‘must give due consideration to evidence that the factfinder could reasonably have found

to be clear and convincing.’” J.L.B., 2017 WL 4942855, at *2 (quoting J.F.C., 96 S.W.3d at 266).

“A [reviewing court] should consider whether disputed evidence is such that a reasonable

factfinder could not have resolved that disputed evidence in favor of its finding.” J.F.C.,

96 S.W.3d at 266. “The [reviewing] court must hold the evidence to be factually insufficient if, in

light of the entire record, the disputed evidence contrary to the judgment is so significant that a

reasonable factfinder could not have resolved that disputed evidence in favor of the ultimate

finding.” In re M.T.C., No. 04-16-00548-CV, 2017 WL 603634, at *2 (Tex. App.—San Antonio

Feb. 15, 2017, no pet.) (mem. op.).

Further, in a bench trial, the trial court is the sole judge of the credibility of witnesses and

the weight to be given their testimony. In re J.F.-G., 627 S.W.3d 304, 312, 317 (Tex. 2021). This

is because “the trial judge is best able to observe and assess the witnesses’ demeanor and

credibility, and to sense the ‘forces, powers, and influences’ that may not be apparent from merely

-3- 04-25-00494-CV

reading the record on appeal.” Coburn v. Moreland, 433 S.W.3d 809, 823 (Tex. App.—

Austin 2014, no pet.) (quoting In re A.L.E., 279 S.W.3d 424, 427 (Tex. App.—Houston [14th

Dist.] 2009, no pet.)). We, therefore, defer to the trial court’s factual determinations and judgment

regarding credibility. J.F.-G., 627 S.W.3d at 312; see also In re R.R.A., 687 S.W.3d 269, 279 n.50

(Tex. 2024) (“Reviewing courts, however, must defer to the factfinder’s judgment as to the

credibility of the witnesses and the weight to give their testimony, including reasonable and logical

inferences from the evidence.”).

BEST INTEREST

In her sole issue, Mother argues the evidence is legally and factually insufficient to support

a finding that termination of her parental rights is in B.H.’s best interest.

When considering the best interest of a child, we recognize the existence of a strong

presumption that the child’s best interest is served by preserving the parent-child relationship. In

re R.R., 209 S.W.3d 112, 116 (Tex. 2006). However, we also presume that prompt and permanent

placement of the child in a safe environment is in the child’s best interest. TEX. FAM. CODE ANN.

§ 263.307(a).

In determining whether a parent is willing and able to provide the child with a safe

environment, we consider the factors set forth in section 263.307(b) of the Texas Family Code. 2

2 These factors include:

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