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

Court of Appeals of Texas·Decided December 14, 2006·No. 02-06-00130-CV·Published

Opinion

                                      COURT OF APPEALS

                                       SECOND DISTRICT OF TEXAS

                                                   FORT WORTH

                                        NO.  2-06-130-CV

IN THE INTEREST OF

R.H. AND J.A.H., CHILDREN                                                                 

                                              ------------

           FROM THE 323RD DISTRICT COURT OF TARRANT COUNTY

                                              ------------

                                MEMORANDUM OPINION[1]

                                              ------------

Appellant L.H. appeals from the trial court=s judgment terminating her parental rights to her minor children, R.H. and J.A.H.  In eight points, L.H.  argues that the evidence is legally and factually insufficient to support the findings made the basis of the trial court=s judgment.  We affirm.

                                      Standards of Review


Termination of parental rights is a drastic remedy and is of such weight and gravity that due process requires the petitioner to justify termination by clear and convincing evidence.  Tex. Fam. Code Ann. '' 161.001, 161.206(a) (Vernon Supp. 2006); In re J.F.C., 96 S.W.3d 256, 263 (Tex. 2002).  This intermediate standard falls between the preponderance standard of ordinary civil proceedings and the reasonable doubt standard of criminal proceedings.  In re G.M., 596 S.W.2d 846, 847 (Tex. 1980); In re K.W., 138 S.W.3d 420, 425 (Tex. App.CFort Worth 2004, pet. denied).  It is defined as the Ameasure 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.@  Tex. Fam. Code Ann. ' 101.007 (Vernon 2002).


The higher burden of proof in termination cases elevates the appellate standard of legal sufficiency review.  J.F.C., 96 S.W.3d at 265.  The traditional no‑evidence standard does not adequately protect the parent=s constitutional interests.  Id.  In reviewing the evidence for legal sufficiency in parental termination cases, we must determine whether the evidence is such that a fact-finder could reasonably form a firm belief or conviction that the grounds for termination were proven.  Id. at 265‑66.  We must review all the evidence in the light most favorable to the finding and judgment.  Id. at 266.  This means that we must assume that the fact-finder resolved any disputed facts in favor of its finding if a reasonable fact-finder could have done so.  Id.  We must also disregard all evidence that a reasonable fact-finder could have disbelieved.  Id.  We must consider, however, undisputed evidence even if it is contrary to the finding.  Id.  That is, we must consider evidence favorable to termination if a reasonable fact-finder could, and disregard contrary evidence unless a reasonable fact-finder could not.  City of Keller v. Wilson, 168 S.W.3d 802, 827 (Tex. 2005).

This higher burden of proof also elevates the appellate standard of factual sufficiency review.  In re C.H., 89 S.W.3d 17, 25 (Tex. 2002).  A[A] finding that must be based on clear and convincing evidence cannot be viewed on appeal the same as one that may be sustained on a mere preponderance.@  Id.  In considering whether the evidence of termination rises to the level of being clear and convincing, we must determine whether the evidence is such that a fact-finder could reasonably form a firm belief or conviction that the grounds for termination were proven.  Id.


The distinction between legal and factual sufficiency lies in how we review the evidence.  J.F.C., 96 S.W.3d at 266.  In a factual sufficiency review, in determining whether the evidence is such that a fact-finder could reasonably form a firm belief or conviction that its finding was true, we must consider whether disputed evidence is such that a reasonable fact-finder could not have resolved it in favor of the finding.  Id.  If, in light of the entire record, the disputed evidence that a reasonable fact-finder could not have credited in favor of the finding is so significant that a fact-finder could not reasonably have formed a firm belief or conviction in the truth of its finding, then the evidence is factually insufficient.  Id.

                                   Summary of the Evidence

L.H. is the mother of R.H. and J.A.H.  In 2002, when R.H. was two years old, the Department of Regulatory and Protective Services (Athe Department@) investigated a report that R.H. had been severely beaten.  Azura Johnson, a Department caseworker, testified that R.H.

Free access — add to your briefcase to read the full text and ask questions with AI

in the Interest of R.H. and J.A.H., Children, (Tex. Ct. App. 2006).

in the Interest of R.H. and J.A.H., Children (in the Interest of R.H. and J.A.H., Children) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

In the Interest of G. M.
596 S.W.2d 846 (Texas Supreme Court, 1980)
Holley v. Adams
544 S.W.2d 367 (Texas Supreme Court, 1976)
In the Interest of S.D.
980 S.W.2d 758 (Court of Appeals of Texas, 1998)
City of Keller v. Wilson
168 S.W.3d 802 (Texas Supreme Court, 2005)
Texas Department of Human Services v. Boyd
727 S.W.2d 531 (Texas Supreme Court, 1987)
In the Interest of J.T.G., H.N.M., Children
121 S.W.3d 117 (Court of Appeals of Texas, 2003)
in the Interest of J.B.W. and K.G., Children
99 S.W.3d 218 (Court of Appeals of Texas, 2003)
in the Interest of M.N.G.
147 S.W.3d 521 (Court of Appeals of Texas, 2004)
in the Interest of R.W.
129 S.W.3d 732 (Court of Appeals of Texas, 2004)
in the Interest of D.S., Jr., a Child
176 S.W.3d 873 (Court of Appeals of Texas, 2005)
In the Interest of D.T.
34 S.W.3d 625 (Court of Appeals of Texas, 2000)
In the interest of C.H.
89 S.W.3d 17 (Texas Supreme Court, 2002)
In the Interest of J.F.C.
96 S.W.3d 256 (Texas Supreme Court, 2002)
In the Interest of J.L.
163 S.W.3d 79 (Texas Supreme Court, 2005)