In the Interest of I.G., a Child v. the State of Texas

CourtTexas Court of Appeals, 7th District (Amarillo)
DecidedJune 16, 2026
Docket07-26-00094-CV
StatusPublished

This text of In the Interest of I.G., a Child v. the State of Texas (In the Interest of I.G., a Child v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 7th District (Amarillo) 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 I.G., a Child v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo

No. 07-26-00094-CV

IN THE INTEREST OF I.G., A CHILD

On Appeal from the 316th District Court Hutchinson County, Texas Trial Court No. 46,060, Honorable James M. Mosley, Presiding

June 16, 2026 OPINION Before PARKER, C.J., and DOSS and PRATT, JJ.

In this accelerated appeal, appellant, Mother, seeks reversal of the trial court’s

judgment terminating her parental rights to her child, I.G., in a suit brought by the Texas

Department of Family and Protective Services. 1 By her appeal, Mother challenges the

sufficiency of the evidence to support the statutory grounds for termination and the best-

interest finding. We affirm the trial court’s judgment.

1 To protect the privacy of the parties involved, we will refer to the appellant as “Mother,” to the

child’s father as “Father,” and to the child by his initials. See TEX. FAM. CODE § 109.002(d); TEX. R. APP. P. 9.8(b). BACKGROUND

Shortly after I.G.’s birth, law enforcement and the Department were called out to

Mother and Father’s home to investigate allegations of physical neglect of I.G. and

methamphetamine use by Mother. Mother refused to cooperate with law enforcement

and left the home. During the Department’s investigation, the concerns of Mother’s

methamphetamine use were validated. The home was found to be in disrepair with no

running water and no crib, diapers, baby wipes, or “anything to indicate that they were

able to take care of a child there.” The Department also learned that three-and-a-half-

month-old I.G. was left with his paternal grandparents. The Department took emergency

possession of I.G., filed its petition for protection, conservatorship, and termination, and

requested emergency temporary managing conservatorship. 2 The trial court entered an

order of emergency protection of I.G. citing a continuing danger to the physical health or

safety of I.G. if he is returned to a parent. Following an adversary hearing, the Department

was appointed temporary managing conservator of I.G. and his placement was continued

with the paternal grandparents. Two of I.G.’s older siblings are also living with the

paternal grandparents, and another sibling is living with the maternal grandparents.

The Department developed a family service plan for Mother, but she was

incarcerated in the Carson County Jail and unable to complete any of the recommended

services. During the pendency of this case, Mother was convicted of possession of

methamphetamine with intent to deliver and sentenced to forty-five years’ incarceration.

Mother did not attend the final hearing.

2 Father’s parental rights were also terminated in this proceeding. Father does not appeal.

2 At the time of the final hearing, I.G. was almost two years old. The permanency

specialist with St. Francis Ministries testified that I.G. is happy, content, and doing very

well in his placement with the paternal grandparents. Upon entering this placement, I.G.

was enrolled in Early Childhood Intervention (ECI) services three times per week to

improve his motor skills and speech development. I.G. is walking and becoming more

verbal. The paternal grandparents are in the process of becoming licensed so that they

can adopt I.G.

The trial court terminated Mother’s parental rights to I.G. on the grounds of

endangering conditions, endangerment, engaging in criminal conduct resulting in her

conviction, imprisonment, and inability to care for I.G. for at least two years from the

original petition’s file date, and causing the child to be born addicted to a controlled

substance. See TEX. FAM. CODE § 161.001(b)(1)(D), (E), (P), (Q). 3 The trial court also

found termination was in the best interest of I.G. See § 161.001(b)(2). The Department

was appointed permanent managing conservator of I.G., and the placement with the

paternal grandparents was continued. Mother timely filed this appeal of the resulting

judgment.

STANDARD OF REVIEW

A parent’s right to the “companionship, care, custody, and management” of his or

her child is a constitutional interest “far more precious than any property right.” Santosky

3 Further references to provisions of the Texas Family Code will be by reference to “section ___”

or “§ ___.”

3 v. Kramer, 455 U.S. 745, 758–59, 102 S. Ct. 1388, 71 L. Ed. 2d 599 (1982); see In re

M.S., 115 S.W.3d 534, 547 (Tex. 2003). We strictly scrutinize termination proceedings

and strictly construe the involuntary termination statutes in favor of the parent. Holick v.

Smith, 685 S.W.2d 18, 20 (Tex. 1985). However, “the rights of natural parents are not

absolute” and “[t]he rights of parenthood are accorded only to those fit to accept the

accompanying responsibilities.” In re A.V., 113 S.W.3d 355, 361 (Tex. 2003) (citing In re

J.W.T., 872 S.W.2d 189, 195 (Tex. 1994)). Recognizing that a parent may forfeit his or

her parental rights by his or her acts or omissions, the primary focus of a termination suit

is protection of the child’s best interests. See id.

In a case to terminate parental rights under section 161.001 of the Family Code,

the petitioner must establish, by clear and convincing evidence, that (1) the parent

committed one or more of the enumerated acts or omissions justifying termination, and

(2) termination is in the best interest of the child. § 161.001(b). Clear and convincing

evidence is “the measure or degree of 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.”

§ 101.007; In re J.F.C., 96 S.W.3d 256, 264 (Tex. 2002). Both elements must be

established, and termination may not be based solely on the best interest of the child as

determined by the trier of fact. Tex. Dep’t of Human Servs. v. Boyd, 727 S.W.2d 531, 533

(Tex. 1987); In re K.C.B., 280 S.W.3d 888, 894 (Tex. App.—Amarillo 2009, pet. denied).

“Only one predicate finding under section 161.001[(b)](1) is necessary to support a

judgment of termination when there is also a finding that termination is in the child’s best

interest.” In re A.V., 113 S.W.3d at 362. We affirm a termination order if the evidence is

both legally and factually sufficient to support any alleged statutory ground the trial court

4 relied upon in terminating parental rights if the evidence also establishes that termination

is in the child’s best interest. In re K.C.B., 280 S.W.3d at 894–95.

In reviewing for legal sufficiency, we 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 the finding was true. In re J.O.A., 283 S.W.3d 336, 344−45

(Tex. 2009). In reviewing for factual sufficiency, we give due consideration to evidence

that the factfinder could reasonably have found to be clear and convincing. In re C.H., 89

S.W.3d 17, 27 (Tex. 2002). If, considering the entire record, the disputed evidence that

a reasonable factfinder could not have credited in favor of the finding is so significant that

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