In the Interest of J.H., A.H., and S.H., Children v. the State of Texas

CourtCourt of Appeals of Texas
DecidedOctober 17, 2024
Docket02-24-00215-CV
StatusPublished

This text of In the Interest of J.H., A.H., and S.H., Children v. the State of Texas (In the Interest of J.H., A.H., and S.H., Children 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 J.H., A.H., and S.H., Children v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-24-00215-CV ___________________________

IN THE INTEREST OF J.H., A.H., AND S.H., CHILDREN

On Appeal from the 324th District Court Tarrant County, Texas Trial Court No. 324-679061-20

Before Birdwell, Bassel, and Wallach, JJ. Memorandum Opinion by Justice Wallach MEMORANDUM OPINION

The trial court terminated the parental rights of S.E.A. (Mother) to her children

Jacob, Aiden, and Sadie.1 In its judgment, the trial court found the predicate termination

grounds in Texas Family Code Section 161.001(b)(1)(D), (E), and (O); found that

termination of Mother’s parental rights was in the children’s best interest; and found

that Mother had not established the defense to Subsection (O) found in Section

161.001(d). See Tex. Fam. Code Ann. § 161.001(b)(1)(D), (E), (O), (d).

On appeal, Mother challenges the legal and factual sufficiency to support the

Subsection (D) and (E) findings and the factual sufficiency of the best-interest finding,

and she argues that the trial court erred by finding that she did not establish the defense

in Section 161.001(d). Because sufficient evidence supports a finding that Mother had

endangered the children and that termination was in the children’s best interest, we will

affirm.

Background

To avoid repetition, we set out here only a general overview of the relevant facts

and procedural history. We include a more detailed recitation below in our analysis of

Mother’s issues.

1 We use aliases to refer to the children and identify family members by their relationship to the children. See Tex. Fam. Code Ann. § 109.002(d); Tex. R. App. P. 9.8(b)(2).

2 In 2022, after receiving a report alleging physical neglect and possible physical

abuse of two of the children, the Department of Family and Protective Services offered

Mother Family Based Safety Services (FBSS). 2 The Department received other reports

concerning the children while the FBSS services were ongoing, and eventually, Mother

asked the Department to take the children in order to give herself time “to get herself

together.”

The Department then filed this child-protection suit and was appointed

temporary managing conservator, and it provided Mother with a service plan. That plan

was later simplified to make it easier for Mother to understand it. Nevertheless, Mother

was unable to complete her services by the time of trial in April 2024. At the conclusion

of the trial, the trial court found the predicate grounds in Section 161.001(b)(1)(D), (E),

and (O), found that Mother had not established the defense in Section 161.001(d), and

found that termination was in the children’s best interest. It subsequently signed an

order terminating Mother’s parental rights. Mother now appeals.

2 “Family-based safety services are protective services provided to a family whose children are not in the conservatorship of the Department.” 40 Tex. Admin. Code § 700.710 (2021) (Dep’t of Fam. & Protective Servs., Services to Families). The Department’s Child Protective Services Division provides these services “to families and children that need . . . assistance to: (1) protect the children from abuse and neglect; (2) help the family reduce the risk of future abuse or neglect; and (3) prevent the removal of the children from their home.” Id.

3 Standard of Review

For a trial court to terminate a parent–child relationship, the party seeking

termination must prove two elements by clear and convincing evidence: (1) that the

parent’s actions satisfy one ground listed in Family Code Section 161.001(b)(1); and

(2) that termination is in the child’s best interest. Id. § 161.001(b); In re Z.N., 602 S.W.3d

541, 545 (Tex. 2020). Evidence is clear and convincing if it “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.” Tex. Fam. Code Ann. § 101.007; Z.N., 602 S.W.3d at 545.

To determine whether the evidence is legally sufficient in parental-termination

cases, we look at all the evidence in the light most favorable to the challenged finding

to determine whether a reasonable factfinder could form a firm belief or conviction

that the finding is true. Z.N., 602 S.W.3d at 545. We disregard all evidence that a

reasonable factfinder could have disbelieved, and we consider undisputed evidence

even if it is contrary to the finding. Id.; In re J.F.C., 96 S.W.3d 256, 266 (Tex. 2002). That

is, we consider evidence favorable to the finding if a reasonable factfinder could, and

we disregard contrary evidence unless a reasonable factfinder could not. In re J.P.B.,

180 S.W.3d 570, 573 (Tex. 2005). When reviewing a finding for factual sufficiency, we

review the whole record to decide whether a factfinder could reasonably form a firm

conviction or belief that the party seeking termination proved the challenged finding.

Tex. Fam. Code Ann. § 161.001(b); In re C.H., 89 S.W.3d 17, 28 (Tex. 2002). If the

4 factfinder reasonably could form such a firm conviction or belief, then the evidence is

factually sufficient. C.H., 89 S.W.3d at 18–19.

Discussion

I. Predicate Termination Grounds

Because it is dispositive of most of Mother’s issues, we begin with her second

issue, which challenges the legal and factual sufficiency of the evidence supporting the

Subsection (E) ground. Subsection (E) allows termination when the parent engaged in

conduct or knowingly placed the child with persons who engaged in conduct that

endangers the child’s physical or emotional well-being. Tex. Fam. Code Ann.

§ 161.001(b)(1)(E).

“Endanger” in this context “means to expose to loss or injury” or “to

jeopardize.” In re J.F.-G., 627 S.W.3d 304, 312 (Tex. 2021) (quoting Tex. Dep’t of Hum.

Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987)). The term “means more than a threat of

metaphysical injury or potential ill effects of a less-than-ideal family environment.” In

re E.N.C., 384 S.W.3d 796, 803 (Tex. 2012) (quoting Boyd, 727 S.W.2d at 533). But the

endangering conduct need not be directed at the child, and the child need not actually

suffer injury. J.F.-G., 627 S.W.3d at 312 (quoting Boyd, 727 S.W.2d at 533). “As a general

rule, conduct that subjects a child to a life of uncertainty and instability” endangers the

child’s physical and emotional well-being. In re R.W., 129 S.W.3d 732, 739 (Tex. App.—

Fort Worth 2004, pet. denied).

5 A. The Evidence

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In the Interest of J.H., A.H., and S.H., Children v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-jh-ah-and-sh-children-v-the-state-of-texas-texapp-2024.