In the Interest of K.H., K.A., K.A., Children v. the State of Texas

CourtTexas Court of Appeals, 11th District (Eastland)
DecidedFebruary 27, 2026
Docket11-25-00255-CV
StatusPublished

This text of In the Interest of K.H., K.A., K.A., Children v. the State of Texas (In the Interest of K.H., K.A., K.A., Children v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 11th District (Eastland) 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 K.H., K.A., K.A., Children v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

Opinion filed February 27, 2026

In The

Eleventh Court of Appeals __________

No. 11-25-00255-CV __________

IN THE INTEREST OF K.H., K.A., AND K.A., CHILDREN

On Appeal from the 326th District Court Taylor County, Texas Trial Court Cause No. 11258-CX

MEMORANDUM OPINION This is an accelerated appeal from the trial court’s order terminating Appellant’s 1 parental rights to two of her children, K.A. and K.A.2. 2 In two issues, Appellant challenges the sufficiency of the evidence to support the trial court’s finding that the termination of her parental rights is in best interest of K.A. and

1 The trial court also terminated the parental rights of the alleged and unknown fathers of K.A., and, in a separate order, it appointed Appellant possessory conservator of her oldest child, K.H. Only the mother filed a notice of appeal, and she does not contest the trial court’s order appointing her as possessory conservator of K.H. 2 We use initials to refer to the children. See TEX. R. APP. P. 9.8(b). K.A.2. See TEX. FAM. CODE ANN. §§ 161.001(b)(2) (West Supp. 2025). We affirm the trial court’s order. I. Termination Findings and Standards The termination of parental rights must be supported by clear and convincing evidence. FAM. § 161.001(b). To terminate one’s parental rights, it must be shown by clear and convincing evidence that the parent has committed one of the acts listed in Section 161.001(b)(1), and that termination is in the best interest of the children. Id. 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.” Id. § 101.007 (West 2019). In this case, the trial court found that clear and convincing evidence established that Appellant: (1) knowingly placed or knowingly allowed K.A. and K.A.2 to remain in conditions or surroundings which endangered the physical or emotional well-being of the children; and (2) engaged in conduct or knowingly placed K.A. and K.A.2 with persons who engaged in conduct which endangered the physical or emotional well-being of the children. See id. § 161.001(b)(1)(D), (E). The trial court further found that termination of Appellant’s parental rights was in K.A.’s and K.A.2’s best interest. See id. § 161.001(b)(2). In reviewing a legal sufficiency challenge, we must decide whether “a reasonable trier of fact could have formed a firm belief or conviction that its finding was true.” In re J.W., 645 S.W.3d 726, 741 (Tex. 2022). Cognizant of the required appellate deference to the factfinder, “we look at all the evidence in the light most favorable to the finding, assume that the factfinder resolved disputed facts in favor of its finding if a reasonable factfinder could do so, and disregard all evidence that a reasonable factfinder could have disbelieved or found to have been incredible.” Id. (internal quotation marks omitted). “However, we may not disregard ‘undisputed facts that do not support the finding,’” and the factfinder is “the sole arbiter of the 2 witnesses’ credibility and demeanor.” Id. (first quoting In re J.F.C., 96 S.W.3d 256, 266 (Tex. 2002); and then quoting In re J.F.-G., 627 S.W.3d 304, 312 (Tex. 2021)). As such, when considering the credibility of the evidence presented, we may not substitute our judgment for that of the factfinder. J.F.-G., 627 S.W.3d at 316. In assessing whether the evidence is factually sufficient, we weigh the disputed evidence that is contrary to the finding against all the evidence that favors the finding. In re A.C., 560 S.W.3d 624, 631 (Tex. 2018). We give due deference to the finding and determine whether, on the entire record, a factfinder could reasonably form a firm belief or conviction about the truth of the allegations against the parent. In re J.O.A., 283 S.W.3d 336, 345 (Tex. 2009); In re C.H., 89 S.W.3d 17, 25–26 (Tex. 2002); In re L.C.C., 667 S.W.3d 510, 512 (Tex. App.—Eastland 2023, pet. denied). Because a trial court conducting a de novo hearing “may also consider the record from the hearing before the associate judge,” we may also do so if it is included in the appellate record, as it is here. See FAM. § 201.015(c) (West 2020); In re A.L.M.-F., 593 S.W.3d 271, 277 (Tex. 2019) (“[R]eview under [S]ection 201.015 is not entirely independent of the proceedings before the associate judge.”). With respect to the best interest of the children, no unique set of factors need be proved. L.C.C., 667 S.W.3d at 513; In re C.J.O., 325 S.W.3d 261, 266 (Tex. App.—Eastland 2010, pet. denied). Further, the best interest determination does not restrict the proof to any specific factor or factors. In re J.S., 687 S.W.3d 541, 547 (Tex. App.—Eastland 2024, no pet.). However, courts may use the non-exhaustive Holley factors to shape their analysis. Holley v. Adams, 544 S.W.2d 367, 371–72 (Tex. 1976). These include, but are not limited to: (1) the desires of the children; (2) the emotional and physical needs of the children now and in the future; (3) the emotional and physical danger to the children now and in the future; (4) the parental abilities of the individuals seeking custody; (5) the programs available to assist these 3 individuals to promote the best interest of the children; (6) the plans for the children by these individuals or by the agency seeking custody; (7) the stability of the home or proposed placement; (8) the acts or omissions of the parent that may indicate the existing parent-child relationship is not a proper one; and (9) any excuse for the acts or omissions of the parent. Id. To support a best interest finding, the Texas Department of Family and Protective Services (the Department) is not required to prove each Holley factor; in some circumstances, evidence of the presence of only one factor will suffice. C.H., 89 S.W.3d at 27; In re D.M., 452 S.W.3d 462, 473 (Tex. App.—San Antonio 2014, no pet.). Additionally, the same evidence that proves one or more statutory grounds for termination may also constitute sufficient, probative evidence illustrating that termination is in the children’s best interest. C.H., 89 S.W.3d at 28; C.J.O., 325 S.W.3d at 266. The absence of evidence of some Holley considerations does not preclude the factfinder from reasonably inferring or forming a strong conviction or belief that termination is in the children’s best interest, particularly if the evidence indicates that the parent-child relationship and the parent’s conduct has endangered the safety and well-being of the children. C.H., 89 S.W.3d at 27. This is so because the best interest analysis evaluates the best interest of the children, not the parent. J.S., 687 S.W.3d at 548; In re E.C.R., 638 S.W.3d 755, 767 (Tex. App.—Amarillo 2021, pet. denied) (citing In re B.C.S., 479 S.W.3d 918, 927 (Tex. App.—El Paso 2015, no pet.)). In this regard, the factfinder may measure a parent’s future conduct by their past conduct in determining whether termination of a parent’s parental rights is in the children’s best interest. J.S., 687 S.W.3d at 548; In re Z.R.M., 665 S.W.3d 825, 829 (Tex. App.—San Antonio 2023, pet. denied); In re D.S., 333 S.W.3d 379, 384 (Tex.

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Bluebook (online)
In the Interest of K.H., K.A., K.A., Children v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-kh-ka-ka-children-v-the-state-of-texas-txctapp11-2026.