in the Interest of J.J.H., R.J.H., J.D.H., and A.J.H., Children

CourtCourt of Appeals of Texas
DecidedFebruary 12, 2020
Docket04-19-00597-CV
StatusPublished

This text of in the Interest of J.J.H., R.J.H., J.D.H., and A.J.H., Children (in the Interest of J.J.H., R.J.H., J.D.H., and A.J.H., Children) 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.J.H., R.J.H., J.D.H., and A.J.H., Children, (Tex. Ct. App. 2020).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-19-00597-CV

IN THE INTEREST OF J.J.H., R.J.H., J.D.H., and A.J.H., Children

From the 45th Judicial District Court, Bexar County, Texas Trial Court No. 2018PA00902 Honorable Charles E. Montemayor, Judge Presiding

Opinion by: Rebeca C. Martinez, Justice

Sitting: Rebeca C. Martinez, Justice Irene Rios, Justice Beth Watkins, Justice

Delivered and Filed: February 12, 2020

AFFIRMED

The appellant (“Mother”) appeals the trial court’s order terminating her parental rights to

her four children, J.J.H., R.J.H., J.D.H., and A.J.H. At the time of trial in August 2019, the children

were ages nine, eight, seven, and six, respectively. In a single issue, Mother challenges the legal

and factual sufficiency of the evidence to support the trial court’s finding that termination is in the

best interest of the children. We affirm.

BACKGROUND

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

involved with Mother and the children in April 2017. At that time, the children were living with

their maternal grandmother in Eagle Pass, Texas, and Mother and the children’s father (“Father”)

were incarcerated in federal prison for the illegal transportation of unauthorized aliens. The 04-19-00597-CV

Department’s caseworker testified that the case began as a family-based case because the two older

children were having behavioral issues at school. These issues included hurting other children and

hurting each other with a lighter.

Mother was released from prison soon after the Department became involved and moved

to a halfway house in Del Rio, Texas. Soon thereafter, Mother moved to the maternal

grandmother’s home in Eagle Pass, and later Mother moved with her children to her own home in

Eagle Pass. In May 2017, Father was released from prison and moved in with Mother and the

children.

Mother testified that in Eagle Pass she worked in a café. When she was at work and when

the children were out of school, the maternal grandmother and Father watched the children.

Mother testified that the maternal grandmother once called Mother at work and told her that Father

was under the influence of drugs. The eldest child also told Mother that Father was using drugs

and “acting crazy” by hitting himself on the walls and hitting his head. Mother testified that Father

hit her many times in front of the children. The children were scared of Father and went to stay

with their maternal grandmother. Mother testified that she separated from Father at that time but,

nevertheless, remained in contact with him. In July 2017, Mother moved with her children to San

Antonio, Texas. According to the caseworker, Mother told her that she moved to get away from

family and from the Department. Mother testified that she moved to attend college but that she

dropped out a month after enrolling. The Department transferred the case from Eagle Pass to San

Antonio.

On April 30, 2018, the Department filed a petition to terminate Mother’s parental rights

because it discovered that Mother had stopped administering the children’s psychiatric medication.

Mother acknowledged at trial that she knew her children needed medication but failed to

administer it. After a three-day bench trial, the trial court terminated Mother’s parental rights to

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her children, concluding that Mother: (1) knowingly placed or knowingly allowed the children to

remain in conditions or surroundings which endangered their physical and emotional well-being;

(2) engaged in conduct or knowingly placed the children with persons who engaged in conduct

which endangered their physical and emotional well-being; and (4) failed to comply with the

provisions of a court order specifically establishing the actions necessary for Mother to obtain the

return of her children. See TEX. FAM. CODE ANN. § 161.001(b)(1)(D), (E), (O). The trial court

also found that termination was in the children’s best interest. Id. § 161.001(b)(2). Mother timely

appealed. In her sole issue, Mother challenges the legal and factual sufficiency of the evidence

supporting the trial court’s best-interest finding.

STANDARD OF REVIEW

A parent-child relationship may be terminated only if the trial court finds by clear and

convincing evidence one of the predicate grounds enumerated in section 161.001(b)(1) of the

Family Code and that termination is in a child’s best interest. Id. § 161.001(b)(1), (2). 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.

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.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.” Id.

“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.” 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

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to be clear and convincing.” Id. “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.

BEST INTEREST

There is a strong presumption that keeping a child with a parent is in a child’s best interest.

In re R.R., 209 S.W.3d 112, 116 (Tex. 2006) (per curiam). However, it is equally presumed that

“the 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 a child with a safe environment, a court should consider: (1) the child’s age and

physical and mental vulnerabilities; (2) the frequency and nature of out-of-home placements; (3)

the magnitude, frequency, and circumstances of the harm to the child; (4) whether the child has

been the victim of repeated harm after the initial report and intervention by the Department or

other agency; (5) whether the child is fearful of living in or returning to the child’s home; (6) the

results of psychiatric, psychological, or developmental evaluations of the child, the child’s parents,

other family members, or others who have access to the child’s home; (7) whether there is a history

of abusive or assaultive conduct by the child’s family or others who have access to the child’s

home; (8) whether there is a history of substance abuse by the child’s family or others who have

access to the child’s home; (9) whether the perpetrator of the harm to the child is identified; (10)

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Bluebook (online)
in the Interest of J.J.H., R.J.H., J.D.H., and A.J.H., Children, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-jjh-rjh-jdh-and-ajh-children-texapp-2020.