In the Interest of J.M., a Child v. the State of Texas

CourtTexas Court of Appeals, 6th District (Texarkana)
DecidedJuly 10, 2026
Docket06-26-00032-CV
StatusPublished

This text of In the Interest of J.M., a Child v. the State of Texas (In the Interest of J.M., a Child v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 6th District (Texarkana) 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.M., a Child v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

In the Court of Appeals Sixth Appellate District of Texas at Texarkana

No. 06-26-00032-CV

IN THE INTEREST OF J.M., A CHILD

On Appeal from the 102nd District Court Bowie County, Texas Trial Court No. 24C0386-102

Before Stevens, C.J., van Cleef and Rambin, JJ. Memorandum Opinion by Chief Justice Stevens MEMORANDUM OPINION

Mother appeals from the trial court’s termination of her parental rights to her child, J.M.1

The trial court terminated Mother’s parental rights after finding that she (1) “knowingly placed

or knowingly allowed the child to remain in conditions or surroundings which endanger the

physical or emotional well-being of the child[;]” (2) “engaged in conduct or knowingly placed

the child with persons who engaged in conduct which endangers the physical or emotional well-

being of the child[;]” (3) “contumaciously refused to submit to a reasonable and lawful order of a

court under Subchapter D, Chapter 261 [of the Texas Family Code]”; and (4) “constructively

abandoned the child.” See TEX. FAM. CODE ANN. § 161.001(b)(1)(D), (E), (I), (N) (Supp.).

Although we conclude that the evidence was insufficient to terminate Mother’s parental rights

under ground (D), we find that legally sufficient evidence supports the unchallenged statutory

grounds for termination as well as under statutory ground (E). We also find that the trial court’s

determination that termination was in J.M.’s best interests is supported by the record. See TEX.

FAM. CODE ANN. § 161.001(b)(2) (Supp.). We, therefore, affirm the judgment, as modified.

1 We use initials to protect the identity of the child and refer to the child’s parents as Mother and Father. See TEX. R. APP. P. 9.8. 2 I. Background2

At the outset of the final hearing, counsel for Mother noted that he had been unable to

maintain contact with Mother, though the case had been “open for a while” and Mother “had

[counsel’s] contact information.” Mother was not present for that hearing.

Ashley Sanders, an investigator with the Department, testified that her involvement in the

case involving Mother and J.M. began in April 2024, when there was an allegation of neglectful

supervision. J.M. was born to Mother while she was incarcerated. Father3 was also incarcerated,

and there was no family able to take care of J.M. Sanders also testified that she was familiar

with Mother because Sanders had been the caseworker in a prior case in Arkansas where Mother

had her parental rights to her four older children terminated. The Department removed J.M., and

after an adversary hearing, the Department was granted temporary managing conservatorship.

The case was then transferred to 4Kids4Families.

Deana Smith was the assigned caseworker from 4Kids4Families in this matter. Smith

testified that Mother received a family-service plan which was made an order of the trial court,

but Mother “didn’t work any of [her] services that [were] on [her] service plan.” Under her

service plan, Mother was required to get a psychological assessment, obtain housing, seek

mental-health services, and submit to drug testing regularly. Smith stated that Mother failed to

2 We note that this matter is back before our Court after a previous reversal and remand. In appellate cause number 06-25-00056-CV, Mother appealed the trial court’s order terminating her rights as to J.M., arguing that the termination order was void because it was based on subsections of the Texas Family Code that were neither pled nor tried by consent. In re J.M., No. 06-25-00056-CV, 2025 WL 3455950 (Tex. App.—Texarkana Dec. 2, 2025, no pet.) (mem. op.). The Texas Department of Family and Protective Services conceded, and we reversed the final order and remanded for further proceedings. Id. at *3. The current appeal comes from the final hearing held after the reversal. 3 Father’s rights to J.M. were also terminated. Father is not a party to this appeal. 3 comply with her family-service plan and that Smith had concerns about Mother’s drug use and

her inability to maintain stable housing or employment. Smith was unable to maintain contact

with Mother due to Mother’s homelessness and Mother’s refusal to accept Smith’s visits when

incarcerated. Smith stated that she believed Mother was unable to meet J.M.’s emotional or

physical needs, that he would be in danger with Mother, and that Mother was unable to

demonstrate parenting abilities. With Mother not having plans for the future or stable housing,

Smith stated she believed termination was in J.M.’s best interests.

Joey Keilbach, a Court Appointed Special Advocate (CASA) coordinator, testified that

J.M. is “precious” and “thriving” in his current placement. J.M. is in a loving, great family that

is “very much” bonded to him. As to Mother, Keilbach stated that he “never had successful

communication” with her, even though Mother was familiar with the termination proceedings

based on the previous termination of her parental rights to her older children. He opined that

Mother was unable to maintain a stable home. Ultimately, Keilbach stated that termination of

Mother’s parental rights was in J.M.’s best interests.

II. Statutory Grounds for Termination

The Texas Supreme Court has recently stated, “[T]he government may not sever the legal

ties between parents and children without clearing a high bar.” In re K.N., No. 24-0881, 2026

WL 1614378, at *6 (Tex. June 5, 2026). Accordingly, “[a] court may terminate a parent’s right

to parent her child if it finds by clear and convincing evidence both that (1) the parent committed

an act prohibited by Section 161.001(b)(1) of the Texas Family Code and (2) termination is in

the best interest of the child.” Id. Here, the trial court found four separate grounds supported

4 termination under Section 161.001(b)(1), grounds (D), (E), (I), and (N); however, on appeal,

Mother only challenges grounds (D) and (E). See TEX. FAM. CODE ANN. § 161.001(b)(1)(D),

(E), (I), (N). By failing to challenge the findings under grounds (I) and (N), Mother waived any

complaint about the sufficiency of the evidence to support those findings. See id. (requiring only

one predicate ground to support termination); In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019)

(per curiam) (stating that “only one ground is required to terminate parental rights”). Therefore,

“if we determine that the evidence was legally sufficient for the [trial court] to have found that

termination was in the best interest[s] of the child, we will affirm the judgment of termination.”

In re A.M.R., 652 S.W.3d 117, 122 (Tex. App.—Waco 2022, pet. denied).

“However, we are also required to consider the sufficiency of the evidence pursuant to

Sections 161.001(b)(1)(D) or (E) if challenged even if the termination is proper as to some other

section, therefore, we will also address one of those grounds.” Id. (citing In re N.G., 577 S.W.3d

230, 235–36 (Tex. 2019) (per curiam)). “This is because a finding under either section could be

used in a subsequent termination of parental rights proceeding.” Id. (citing TEX. FAM. CODE

ANN. § 161.001(b)(1)(M)).

A. Standard of Review

“Proceedings to terminate the parent–child relationship implicate[s] rights of

constitutional magnitude that qualify for heightened judicial protection.” In re A.C., 560 S.W.3d

624, 626 (Tex. 2018). The United States Supreme Court has emphasized that “the interest of [a]

parent[] in the care, custody, and control of their children . . .

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