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

Texas Court of Appeals, 2nd District (Fort Worth)·Decided January 30, 2026·No. 02-25-00524-CV·Published

Opinion

In the

Court of Appeals Second Appellate District of Texas at Fort Worth

No. 02-25-00524-CV

IN THE INTEREST OF I.H., A CHILD

On Appeal from the 324th District Court Tarrant County, Texas

Trial Court No. 324-760222-24

Before Sudderth, C.J.; Wallach and Walker, JJ. Memorandum Opinion by Justice Wallach

MEMORANDUM OPINION

A trial court terminated Mother’s and Father’s parental rights to their child, Ann.1 Both appealed.

Mother’s counsel filed a brief in which he asserted that her appeal was frivolous. After independently reviewing the record, we agree with counsel and affirm the judgment terminating her parental rights.

In contrast, Father filed a brief asserting four issues: (1) the trial court violated the United States and Texas Constitutions by denying his counsel’s request for time to have Father brought from jail to attend trial; (2) the evidence is legally and factually insufficient to support the trial court’s finding that he had knowingly placed or knowingly allowed Ann to remain in conditions or surroundings that endangered her physical or emotional well-being, see Tex. Fam. Code Ann. § 161.001(b)(1)(D); (3) the evidence is legally and factually insufficient to support the trial court’s finding that he had engaged in conduct or knowingly placed Ann with persons who had engaged in conduct that endangered her physical or emotional well-being, see id. § 161.001(b)(1)(E); and (4) the evidence is legally and factually insufficient to support the trial court’s finding that termination of his parental rights was in Ann’s best interest, see id. § 161.001(b)(2). We overrule Father’s first issue because he failed to

1 To protect the child’s identity, we use an alias when referring to her and refer to her family members by their relationship to her. See Tex. Fam. Code Ann. § 109.002(d); Tex. R. App. P. 9.8(b)(2).

preserve any constitutional complaints at trial. We decline to address his second issue—his attack on the Subsection (D) finding—because our disposition of his third issue makes resolving this issue unnecessary. See Tex. R. App. P. 47.1. We overrule Father’s third issue because the evidence is both legally and factually sufficient to support the trial court’s Subsection (E) finding. And we overrule his fourth issue because the evidence is both legally and factually sufficient to support the trial court’s finding that termination was in Ann’s best interest. Having overruled Father’s first, third, and fourth issues and having determined that resolving his second issue is unnecessary, we affirm the judgment terminating his parental rights.

I. MOTHER

Mother’s court-appointed appellate counsel has filed an Anders brief in which he concluded that her appeal is frivolous and without merit. See Anders v. California, 386 U.S. 738, 744, 87 S. Ct. 1396, 1400 (1967); In re P.M., 520 S.W.3d 24, 27 & n.10 (Tex. 2016). Counsel’s brief meets the requirements of Anders by presenting a professional evaluation of the record and showing why she has no arguable grounds to advance on appeal. See Anders, 386 U.S. at 744, 87 S. Ct. at 1400; Taylor v. Tex. Dep’t of Protective & Regul. Servs., 160 S.W.3d 641, 646–47 (Tex. App.—Austin 2005, pet. denied). Counsel has certified that he has mailed to Mother at her last known address a copy of his Anders brief and informed her of her right to examine the appellate record and to file a pro se response.

We gave Mother until December 18, 2025, to notify us if she wished to file a pro se response to counsel’s Anders brief. We received no response. The Department filed a letter in which it agreed with Mother’s counsel that she had no meritorious grounds to advance on appeal.

On receiving an Anders brief, we must independently examine the record to determine whether the appeal is wholly frivolous. See Penson v. Ohio, 488 U.S. 75, 80, 109 S. Ct. 346, 350 (1988); Taylor, 160 S.W.3d at 647. After reviewing the record, we agree with Mother’s counsel that any issue that she might raise would be frivolous. Accordingly, we affirm the trial court’s judgment terminating her parental rights.

II. FATHER

A. Background At birth in November 2024, Ann’s umbilical cord and meconium both tested positive for methamphetamines. That same month, the Texas Department of Family and Protective Services (the Department) obtained an ex parte order removing Ann from Mother and Father and appointing the Department as her temporary sole managing conservator.

When speaking to a Department investigator, Father admitted to having a history of using methamphetamines “on and off from the age of [fifteen]” but maintained that he had been sober for two years. Father further admitted having a recent drug charge. To a caseworker, Father later admitted that he smoked marijuana and that he and Mother had smoked methamphetamines together.

Despite asserting that he no longer used drugs other than marijuana, Father refused to take drug tests. Father told a caseworker that if he were tested, “there would probably be more substances in his system . . . than marijuana.” Because Father had refused to take a drug test, the caseworker stated that the Department would have presumed that the “test would’ve been positive for more illegal drugs than just marijuana.”

The record also showed that Father had been indicted for possession of less than one gram of methamphetamines in 2020, had been placed on deferred adjudication community supervision for that offense in 2022, and had been adjudicated guilty of that offense in 2023. In the motion to revoke unadjudicated community supervision, the State alleged that Father had possessed a controlled substance—without identifying the substance—in May 2023. Father, however, pled true to other allegations that did not involve the possession of a controlled substance, and based on those pleas of true, he was adjudicated guilty of the original possession offense.

The caseworker determined that Father did not work. For finances, Father explained that he donated plasma. Father entertained the possibility of filing for disability because of his own mental stress.

The caseworker learned that Father and Mother lived in a trailer home that purportedly belonged to Paternal Grandfather. The caseworker was never given permission to go inside. Not seeing the interior concerned the caseworker because the

agency had a policy that required caseworkers to see the inside of a home if a child was going to be living there. Father told the caseworker that the trailer he lived in was not stable and explained that it had plumbing and electrical issues. He conceded to the caseworker that he would not be able to care for his baby there.

When a caseworker visited Father at his home in late May, he stated that there was a pending eviction. The caseworker testified that when she went to Father’s trailer in late July, she discovered that his trailer was no longer there and had been torn down. The caseworker found Mother at her friend’s home, and Mother indicated that Father was living in a tent in a field. For safety reasons, the caseworker declined to go to the location.

In late August, the caseworker found Mother at another man’s home. Mother told the caseworker that Father had moved his tent to a field in front of a Whataburger, but after going to that location, the two women were not able to find him. Mother then told the caseworker that Father might have gone to the house in which Paternal Grandfather was living, but their attempts to locate the house also failed.

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