In the Interest of V.A. and L.A., Children v. the State of Texas

Court of Appeals of Texas·Decided November 26, 2025·No. 04-25-00396-CV·Published

Opinion

Fourth Court of Appeals

San Antonio, Texas

MEMORANDUM OPINION

No. 04-25-00396-CV

IN THE INTEREST OF V.A. and L.A., Children

From the 73rd Judicial District Court, Bexar County, Texas Trial Court No. 2024PA00434 Honorable Raul Perales, Associate Judge Presiding

Opinion by: Rebeca C. Martinez, Chief Justice Dissenting Opinion by: Lori Massey Brissette, Justice

Sitting: Rebeca C. Martinez, Chief Justice Lori Massey Brissette, Justice H. Todd McCray, Justice

Delivered and Filed: November 26, 2025 AFFIRMED This appeal arises from the trial court’s order, signed after a bench trial, that terminates the parental rights of appellant J.A. (“Father”), the biological father of V.A. and L.A. (collectively the “Children”). 1 In four issues, Father argues that the evidence is legally and factually insufficient to support the trial court’s findings on the predicate grounds and best interest. See TEX. FAM. CODE ANN. § 161.001(b)(1)(D)–(E), (O), (b)(2). We affirm.

1 To protect the identities of the minor children in this appeal, we refer to the Children and their family members by initials or pseudonyms. See TEX. FAM. CODE ANN. § 109.002(d); TEX. R. APP. P. 9.8(b)(2).

I. BACKGROUND

In March 2024, the Texas Department of Family and Protective Services (the “Department”) initiated the underlying proceeding by filing a petition to terminate the parental rights of Father and A.T. (“Mother”), the biological mother of the Children. Thereafter, the trial court signed an “Order for Protection of a Child in an Emergency” that, among other things, appointed the Department as the Children’s “temporary sole managing conservator.” Father signed a family service plan, and it was adopted and incorporated into a court order. Meanwhile, the Children were placed with paternal great aunt (“Great Aunt”) and great uncle (“Great Uncle”).

In April 2025, the bench trial commenced. Father was represented by counsel, but he did not personally attend the trial. At the time of trial, V.A. was four years old, and L.A. was three years old. At the trial’s conclusion, the trial court found by clear and convincing evidence that: (1) Father allowed the Children to remain in a physically or emotionally dangerous condition or surrounding (subsection (1)(D) endangerment by conditions or surroundings); (2) Father engaged in conduct or knowingly placed the Children with persons who engaged in conduct which endangers the physical or emotional well-being of the Children (subsection (1)(E) endangerment by conduct); (3) Father failed to comply with specific provisions of a court order (subsection (1)(O) failure to comply with court order); and (4) termination of Father’s parental rights is in the best interest of the Children (subsection (2) best interest). See id. The trial court signed an order that terminated Father’s parental rights and appointed the Department as the Children’s permanent managing conservator.

Father timely appeals from the termination order. 2

2 The termination order also terminated the parental rights of Mother. Mother does not appeal, and she is not a party to this appeal.

II. DISCUSSION

A. Standard of Review A parent-child relationship may be terminated, pursuant to section 161.001 of the Texas Family Code, only if the trial court finds by clear and convincing evidence one of the predicate grounds enumerated in subsection (b)(1) and that termination is in a child’s best interest. See 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.

We review the legal and factual sufficiency of the evidence under the standards of review established by the Texas Supreme Court in In re J.F.C., 96 S.W.3d 256, 266–67 (Tex. 2002). In reviewing the legal sufficiency of the evidence, 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.” Id. at 266. “[A] reviewing court must assume that the factfinder resolved disputed facts in favor of its finding if a reasonable factfinder could do so.” Id. In reviewing the factual sufficiency of the evidence, we “must give due consideration to evidence that the factfinder could reasonably have found 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. B. Law on Endangerment Subsection 161.001(b)(1)(D) allows a trial court to terminate a parent’s rights if the court finds by clear and convincing evidence that the parent “knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endanger the physical or emotional well-

being of the child[.]” TEX. FAM. CODE ANN. § 161.001(b)(1)(D). Subsection (E) allows a trial court to terminate a parent’s rights if the court finds by clear and convincing evidence that the parent “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.” Id. § 161.001(b)(1)(E). Endangerment means to expose to loss or injury, to jeopardize. See Tex. Dep’t of Human Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987); see also In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam).

“While both subsections (D) and (E) focus on endangerment, they differ regarding the source and proof of endangerment.” In re N.M.R., No. 04-22-00032-CV, 2022 WL 3640223, at *3 (Tex. App.—San Antonio Aug. 24, 2022, pet. denied) (mem. op.). “Subsection D concerns the child’s living environment, rather than the conduct of the parent, though parental conduct is certainly relevant to the child’s environment.” Id. (citing In re J.T.G., 121 S.W.3d 117, 125 (Tex. App.—Fort Worth 2003, no pet.)). Under subsection (E), the cause of the endangerment must be the parent’s conduct and must be the result of a conscious course of conduct rather than a single act or omission. In re J.T.G., 121 S.W.3d at 125.

In certain instances, the evidence supporting the trial court’s finding of subsection (D)

endangerment is intertwined and overlaps with the evidence supporting the trial court’s subsection (E) endangerment finding. Id. at 131. In such instances, we may consolidate our review of the evidence supporting these findings. Id.; see also In re J.J.V.M.M., No. 04-22-00405-CV, 2022 WL 17479144, at *2 (Tex. App.—San Antonio Dec. 7, 2022, no pet.) (mem. op.) (consolidating examination of subsections (D) and (E) findings).

C. Endangerment Evidence At trial, Oscar Aguilar, a family-based caseworker with Child Protective Services, testified as to four areas of concern. First, on or about November 7, 2022, the Department began an investigation because a complaint was made about L.A. crying, two slaps being heard, and L.A. continuing to cry. Aguilar emphasized that Father was the only person in the room with L.A. This incident, according to information that Aguilar received, resulted in L.A. having bruising, swelling, and redness to her eye that necessitated evaluation by emergency medical services (“EMS”). The incident prompted the Department to offer Father individual counseling, random drug testing, and substance abuse treatment.

Second, Aguilar recounted that there were allegations Father had engaged in domestic violence against Mother while the Children were in the home. There were also allegations that Mother had engaged in domestic violence against Father’s cousin. The Children’s potential exposure to domestic violence was a concern from the outset of the underlying proceeding. In a family service plan signed by Father on April 25, 2024, and admitted into evidence at trial, an area of concern was:

Intimate Partner Violence

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In the Interest of V.A. and L.A., Children v. the State of Texas, (Tex. Ct. App. 2025).

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