Tex. Fam. Code Ann. § 161.001

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being; violent and criminal conduct can support that finding.

In the Interest of M.H. and M.H., Children v. the State of Texas · filed 2024-12-12(b)(1)(E)

Accordingly, the evidence is factually—and thus legally—sufficient to support the trial court’s Subsection (E) finding.

Continued drug use can establish an endangering course of conduct under subsection (b)(1)(E).

In the Interest of A.L., a Child v. the State of Texas · filed 2024-11-26(b)(1)(E)

Under the applicable standards of review, we conclude that the evidence is legally and factually sufficient to support the trial court’s predicate finding of endangerment under section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) requires sufficient evidence to support termination on that predicate ground.

D.M.K. and S.M. v. Department of Family and Protective Services and J.S. and B.S. · filed 2024-10-10(b)(1)(E)

We reverse the portion of the final order of the trial court with respect to the conclusion that the evidence was sufficient to support termination on the predicate ground of Family Code Section 161.001(b)(1)(E), and we render the judgment the trial court should have rendered, with the result that we strike the conclusion that the evidence was sufficient to support termination under subsection (E).

Subsection (b)(1)(E) permits a court to consider a parent’s endangering conduct toward a child’s siblings when deciding whether the parent endangered the child.

In the Interest of F.S., a Child v. the State of Texas · filed 2024-10-09(b)(1)(E)

Although F.S. was in Father’s custody for about five months, the trial court could consider Father’s endangering conduct while he had custody of F.S.’s siblings.

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows a parent’s course of conduct endangered the child’s physical or emotional well-being.

In the Interest of F.S.F., a Child v. the State of Texas · filed 2024-08-14(b)(1)(E)

Further, after considering the entire record, including any disputed or contrary evidence, we conclude the evidence is factually sufficient to support the trial court’s termination under subsection 161.001(b)(1)(E) of the Texas Family Code.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being, including conduct before the child’s birth.

In the Interest of J.F. and J.F., Children v. the State of Texas · filed 2024-07-25(b)(1)(E)

Viewing the evidence in the light most favorable to the trial court’s judgment, we conclude a reasonable trier of fact could have formed a firm belief or conviction that Father “engaged in conduct . . . which endanger[ed] the physical or emotional well-being of the child[ren].” See TEX. FAM. CODE ANN. § 161.001(b)(1)(E).

Section 161.001(1) treats parental conduct as endangering a child when it jeopardizes the child’s well-being, even if the conduct is not directed at the child and causes no actual injury.

In the Interest of J.J. & K.J. · filed 1995-10-31(1)

In order for parental conduct to constitute endangerment of a child’s well-being, it is not necessary that the conduct be directed at the child or that the child actually suffer injury; rather, it is sufficient that the child’s well-being be jeopardized or exposed to loss or injury.

Section 161.001(1)(E) does not require proof that a parent’s conduct caused an actual adverse effect on the child.

In the Interest of B.R. · filed 1997-05-08(1)(E)

Contrary to his view of Section 161.001(1)(E), the statute does not require a showing that a parent’s conduct caused an actual adverse effect upon the child.

Section 161.001(1)(E) requires a course of parental conduct that endangers a child’s physical or emotional well-being.

In the Interest of R.D. · filed 1997-10-16(1)(E)

Instead, subsection E is satisfied simply by showing a parental course of conduct endangered the child’s physical or emotional well-being.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent's course of conduct endangered a child's physical or emotional well-being.

Spangler v. Texas Department of Protective & Regulatory Services · filed 1998-02-04(1)(E)

If the evidence shows a course of conduct on Spangler's part "which has the effect of endangering the physical or emotional well-being of" his children, a finding under § 161.001(1)(E) will be upheld. ... Based on this evidence, the jury could have reasonably found by clear and convincing evidence that Spangler engaged in a course of conduct which endangered his daughters' physical or emotional well-being such that termination of his parental rights was appropriate.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows a parent’s conduct endangered a child’s physical or emotional well-being and termination is in the child’s best interest.

Spangler v. Texas Department of Protective and Regulatory Services · filed 1998-02-04(1)(E)

Under the clear and convincing standard of review, we find that the jury reasonably could have found that Spangler engaged in conduct or knowingly placed the children with persons who have engaged in conduct which endangered the physical or emotional well-being of his children.

Section 161.001(1)(E) requires the parent’s acts or omissions to directly cause endangerment of the child.

in the Interest of M.D., a Child · filed 1998-04-16(1)(E)

Subsection E requires that the parent’s conduct be the direct cause of the endangerment, as evidenced by both the parent’s acts and omissions.

Section 161.001(1)(E) permits termination when a parent's voluntary course of conduct endangers the child's emotional well-being, even if the conduct was not directed at the child.

In Re KMM · filed 1999-04-01(1)(E)

The trial court may order termination of the father's parental rights if it finds that one or more of the grounds listed in TEX. FAM. CODE ANN. § 161.001 (Vernon Supp.1999) exist and that termination is in the best interest of the child. We find that the trial court was correct in finding that appellant engaged in conduct that endangered the physical or emotional well-being of the child. Section 161.001(1)(E).

Section 161.001(1)(E) permits termination when a parent's voluntary course of conduct endangers a child's physical or emotional well-being, even if the conduct was not directed at that child.

In the Interest of K.M.M. · filed 1999-04-01(1)(E)

The trial court may order termination of the father’s parental rights if it finds that one or more of the grounds listed in TEX. FAM. CODE ANN. § 161.001 (Vernon Supp.1999) exist and that termination is in the best interest of the child. We find that the trial court was correct in finding that appellant engaged in conduct that endangered the physical or emotional well-being of the child. Section 161.001(1)(E).

Section 161.001 permits a finding of endangerment based on a parent's misconduct even if the parent never physically possessed the child.

Robert Rojas, Sr. v. Texas Department of Protective and Regulatory Services · filed 1998-02-12(1)(D), (1)(E)

Rojas argues that because he never had physical possession of the child there is no way he could have endangered the "physical or emotional well-being of the child" as required by section 161.001(D) & (E). We disagree. "Danger" to a child can be inferred from parental misconduct alone.

Conduct endangering one child can support termination as to another child in the household even when the conduct was not directed at that child.

Lou Ann Krauss Baetz v. Texas Department of Protective and Regulatory Services · filed 1998-12-10(1)(E)

Because conduct endangering one child places all children in the household in jeopardy, the conduct required to support this finding need not be directed toward Dustin.

Under section 161.001(1)(E), abuse directed at the other parent can establish endangerment of a child.

Hogeda v. Mendez-Dotson · filed 1998-12-29(1)(E)

It is not necessary for a finding that a person engaged in conduct that endangered the physical and emotional well-being of a child that the abusive conduct be directed at the child.

Section 161.001(1)(E) permits endangerment to be inferred from a parent’s sexual assault of another child in the home without proof that the parent’s child suffered actual injury.

In the Interest of King · filed 2000-03-23(1)(E)

The aggravated sexual assault of a child living in the home with the child whose parental rights are in question is conduct that we may infer will endanger or jeopardize the well-being, both physical and emotional, of other children in the home who may discover the abuse or be abused themselves. Section 161.001(1)(E) does not require such actual injury before a parent’s parental rights may be terminated.

Section 161.001(1)(E) permits termination when a parent's course of conduct endangers the child's physical or emotional well-being, including conduct before the child's birth.

In Re SF · filed 2000-09-29(1)(E)

Hanes's criminal behavior before his imprisonment and S.F.'s birth, along with his continued misbehavior during his prison stay shows Hanes has engaged in a course of conduct that would be detrimental to S.F. We find this evidence was factually sufficient to produce in the mind of the trial judge a firm belief that by his course of conduct, Hanes's behavior endangered S.F.'s physical or emotional well being.

Section 161.001(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being, even if the conduct occurs outside the child's presence.

Paige Cox and Tawnya Cox v. Texas Department of Protective and Regulatory Services · filed 2000-10-05(1)(E)

After an extensive review of the record, we hold that the district court had clear and convincing evidence that is legally and factually sufficient to support the findings that appellants' course of conduct endangered S.H.C.'s emotional or physical well-being despite the fact that all of the events occurred outside S.H.C.'s presence.

Section 161.001(1)(E) does not permit termination based on poverty alone without evidence that poverty endangered the child.

Doyle v. Texas Department of Protective & Regulatory Services · filed 2000-05-03(1)(E)

In the absence of such evidence, we will not conclude that a showing of poverty, standing alone, demonstrates endangerment under this section.

Section 161.001(1)(E) allows courts to consider a parent’s conduct before and after a child’s birth when deciding whether the parent engaged in a course of conduct that endangered the child.

In the Interest of M.J.M.L. · filed 2000-09-27(1)(E)

However, no court has held, and we do not find that the statutory definition of “child” conflicts with a definition of a course of conduct endangering a child which incorporates conduct occurring before and after a child’s birth.

Evidence of endangering conduct was legally sufficient to support termination under subsection (1)(E).

In the Interest of J.O.C. · filed 2001-04-25(1)(E)

Consequently, we find that the record contains legally sufficient evidence to support an involuntary termination under Section 161.001(1)(E) of the Family Code.

Under subsection (1)(E), a parent’s conduct can endanger a child even if it is not directed at the child and causes no actual injury.

In the Interest of N.K. · filed 2001-08-16(1)(E)

In order for parental conduct to constitute endangerment of the children’s well-being, the conduct need not be directed at the children and the children need not actually suffer injury.

Clear and convincing evidence of endangering conduct supported termination under subsection (1)(E).

In the Interest of W.C. · filed 2001-09-06(1)(E)

Therefore, we find there was legally sufficient evidence to enable a factfinder to determine by clear and convincing evidence that appellant engaged in conduct which endangered the physical and emotional well-being of the child.

A parent's conduct can endanger a child even if it is not directed at the child and causes no actual injury.

In Re NK · filed 2001-09-18(1)(E)

In order for parental conduct to constitute endangerment of the children's well-being, the conduct need not be directed at the children and the children need not actually suffer injury. Rather, endanger means to expose to loss or injury, to jeopardize.

Section 161.001(1)(E) treats a voluntary course of parental conduct that endangers a child's physical or emotional well-being as a ground for termination.

In Re DM · filed 2001-10-04(1)(E)

We conclude that, viewing the evidence most favorably to the jury's verdict, there is legally sufficient evidence of a voluntary, deliberate, and conscious course of conduct by Appellant from which the jury could reasonably conclude there was a high probability that her conduct endangered the children's emotional or physical well-being. Viewing all the evidence in the record in a neutral light, both that favoring termination and that favoring maintaining Appellant's parental rights, we conclude there is also factually sufficient evidence that Appellant engaged in conduct that endangered the children's physical and emotional well-being.

Section 161.001(1)(E) requires a course of parental conduct that endangers the child; a single act or omission is insufficient.

In the Interest of D.P., a Child · filed 2001-11-28(1)(E)

We first address the contention that Cordell engaged in conduct that endangered D.P. which is part of the requirement under section 161.001(1)(E). Termination under this provision may not be based on a single act or omission, but a showing of a course of conduct is required.

Section 161.001(1)(E) permits a parent's conduct toward one child to establish endangerment of another child, even without proof that the other child was injured.

Davis v. Texas Department of Protective and Regulatory Services · filed 2001-12-13(1)(E)

Misconduct directed towards one child can support a finding that the parent engaged in a course of conduct that endangered another child.

Section 161.001(1)(E) permits termination for conduct endangering a child even if the conduct was not directed at the child and caused no actual injury.

in the Interest of H. R. S., a Child · filed 2002-02-26(1)(E)

Second, one need not prove that the misconduct creating the danger was directed at the child or that the child actually suffered injury to succeed in terminating parental rights.

Section 161.001(1)(E) covers parental acts and omissions that endanger a child without requiring proof that the conduct caused actual harm.

in the Interest of A. N. L., a Child · filed 2002-03-26(1)(E)

The State was not required to establish that Lamb's conduct actually caused A.N.L.'s malnourishment. It was required to establish only that Lamb's conduct, including both acts and omissions, posed a danger to A.N.L., exposing A.N.L. to loss or injury.

Section 161.001(1)(E) is satisfied when imprisonment forms part of a course of conduct that endangers a child.

Lola Garcia and Willie Thompson, Jr. v. Texas Department of Protective and Regulatory Services · filed 2002-08-30(1)(E)

Thus, if the evidence, including imprisonment, proves a course of conduct that has the effect of endangering the child, the requirement of section 161.001(1)(E) is met.

Failure to take medication that leaves a parent unable to care for a newborn can constitute endangering conduct under Section 161.001(1)(E).

in the Interest of S.A.A., a Child · filed 2002-09-13(1)(E)

The trial court could have discounted this testimony, reasoning that appellant's endangerment of S.A.A. was not a case of active conduct as the passive conduct of failure to take her medication, thus disabling her from taking care of herself and incapacitating herself from meeting the physical and emotional needs of a newborn child. ... We hold the evidence is factually sufficient for the trial court to have reasonably formed a firm belief or conviction that appellant had engaged in conduct which endangered the physical or emotional well-being of S.A.A.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows a parent’s conduct endangered a child’s emotional well-being; one statutory ground is sufficient.

Robinson v. Texas Department of Protective & Regulatory Services · filed 2002-09-30(1)(E)

Viewing all the evidence in the record, we conclude the evidence is factually sufficient to reasonably form a firm belief that appellant engaged in conduct that endangered her children’s emotional well-being. Because we have concluded the evidence is factually sufficient to support the trial court’s findings under section 161.001(1)(E), we need not address the sufficiency of the evidence under section 161.001(1)(D). Only one finding alleged under section 161.001(1) is necessary for a judgment of termination.

Section 161.001(1)(E) permits a finding of endangering conduct based on a parent's continued illegal drug use despite a reunification plan.

Robinson, Lisa v. Texas Department of Protective and Regulatory Services · filed 2002-09-30(1)(E)

We conclude that appellant's illegal drug activity, a violation of community supervision after agreeing not to commit such acts in the Plan for reunification with her children, established clear and convincing proof of voluntary, deliberate, and conscious conduct that endangered the well-being of her children.

Section 161.001(1)(E) requires a course of parental conduct that endangers a child's physical or emotional well-being.

Porter v. the Texas Department of Protective and Regulatory Services · filed 2003-03-06(1)(E)

To support a finding under paragraph (E) of section 161.001(1), the evidence must show that the parent engaged in a course of conduct which endangered the children's physical and emotional well-being.

Subsection (1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being, even if the child suffers no actual injury.

in the Interest of N.N.S. and J.D.L.S., Minors · filed 2002-11-21(1)(E)

The facts set forth above constitute "more than a scintilla" of evidence that Shinkle engaged in a course of conduct that endangered the physical or emotional well-being of his children.

Section 161.001(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being; imprisonment may be considered as part of that course.

in the Interest of R.G., S.G., and B.L., Children · filed 2003-03-27(1)(E)

We hold that the evidence was both legally and factually sufficient to support the trial court’s grant of termination under subsection E.

Subsection (1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being.

in Re: D.S., a Minor Child · filed 2003-04-24(1)(E)

Accordingly, we find the evidence presented was legally sufficient to support the trial court’s finding that appellant endangered D.S. and violated section 161.001(1)(E).

Section 161.001(1)(E) requires evidence that a parent engaged in a course of conduct endangering the children’s physical and emotional well-being.

Porter v. Texas Department of Protective & Regulatory Services · filed 2003-05-29(1)(E)

To support a finding under paragraph (E) of section 161.001(1), the evidence must show that the parent engaged in a course of conduct which endangered the children’s physical and emotional well-being.

Clear and convincing evidence that a parent engaged in endangering conduct or knowingly placed a child with someone who did can support termination if termination is also in the child’s best interest.

Garcia v. Texas Department of Protective and Regulatory Services · filed 2003-06-26(1)(E)

The evidence in this cause is legally and factually sufficient for a reasonable trier of fact to form a firm conviction that Garcia engaged in conduct or knowingly placed her children with persons who engaged in conduct which endangered the children.

Section 161.001(1)(E) permits termination when a parent's drug use and resulting incarceration are part of a course of conduct that endangers a child.

Carlos Smith and Bobbie Hinojosa Smith v. Texas Department of Protective and Regulatory Services · filed 2003-09-11(1)(E)

In this case, the evidence proves that Carlos's incarceration due to his drug use and Bobbie's drug use are part of a course of conduct endangering their children.

Section 161.001(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being.

In Re RF · filed 2003-09-29(1)(E)

After reviewing all the evidence, we conclude the jury could reasonably form a firm belief or conviction that appellant engaged in conduct that endangered the physical or emotional well-being of her children as set out in subsection (E). Under subsection (E), the cause of danger to the child must be the parent's conduct alone, including the parent's actions or omissions or failures to act.

Section 161.001(1)(E) permits termination when a parent’s acts or omissions endanger a child’s physical or emotional well-being.

In Re the Interest of R.F. · filed 2003-09-29(1)(E)

After reviewing all the evidence, we conclude the jury could reasonably form a firm belief or conviction that appellant engaged in conduct that endangered the physical or emotional well-being of her children as set out in subsection (E). Under subsection (E), the cause of danger to the child must be the parent’s conduct alone, including the parent’s actions or omissions or failures to act.

Section 161.001(E) does not require proof that a parent intended to harm the child; conduct that endangers the child's physical or emotional well-being is enough.

in the Interest of K. W. and C. G. III · filed 2003-09-30(E)

And the Family Code does not require a showing that T.K. intentionally engaged in violence in an effort to harm the children; it is enough that she engaged in conduct (no matter who started it) endangering the physical or emotional well-being of C.G.

Section 161.001(1)(E) permits termination when a parent knowingly leaves another child with someone who has abused that child.

In the Interest of C.J.F., a Child · filed 2003-11-25(1)(E)

Likewise, the singular fact that Brenda allowed N.T. to remain unattended in the company of one she knew had abused him in the past provides a basis for termination of her parental rights to C.J.F. under section (E).

Section 161.001(1)(E) requires a course of conduct that endangers a child's physical or emotional well-being.

In Re AB · filed 2003-12-31(1)(E)

Subsection (D) permits termination based on a single act or omission, while subsection (E) requires a "course of conduct." ... The evidence is legally and factually sufficient to support the finding that Palmer engaged in conduct or knowingly placed the children with persons who engaged in conduct which endangered the physical or emotional well-being of the children.

Section 161.001(1)(E) requires a voluntary, deliberate, and conscious course of parental conduct that endangers a child's physical or emotional well-being.

In Re RW · filed 2004-02-05(1)(E)

Termination under section 161.001(1)(E) must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required.

Section 161.001(1)(E) permits a finding of endangerment based on a parent's course of conduct even if the child has not yet suffered injury.

In Re ST · filed 2004-02-05(1)(E)

Again, to "endanger" a child for purposes of the statutory termination provisions, the parent's acts or omissions in question need not be directed at the child and the child need not have yet suffered injury. Texas Dep't of Human Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex.1987). If the evidence shows a course of conduct which has the effect of endangering the physical or emotional well-being of the child, a finding under section 161.001(1)(E) is supportable.

Section 161.001(1)(E) requires a voluntary, deliberate, and conscious course of conduct that endangers a child; a single act or omission is insufficient.

in the Interest of R.W. · filed 2004-02-05(1)(E)

Termination under section 161.001(1)(E) must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required.

Section 161.001(1)(E) permits termination when a parent knowingly fails to protect another child from abuse and that conduct endangers the child whose parental relationship is at issue.

In Re CJF · filed 2003-11-25(1)(E)

Likewise, the singular fact that Brenda allowed N.T. to remain unattended in the company of one she knew had abused him in the past provides a basis for termination of her parental rights to C.J.F. under section (E).

Section 161.001(1)(E) treats cocaine use during pregnancy as conduct that can endanger a child’s physical or emotional well-being.

in the Interest of S. E. L., II, a Minor Child · filed 2003-12-04(1)(E)

Based on this evidence, we conclude the trial court had sufficient evidence before it to produce in its mind a firm belief or conviction that appellant engaged in conduct that endangered S.E.L., II’s physical and emotional well-being.

A parent's course of neglect can support a conduct endangerment finding for a child who was never in the parent's custody.

in the Interest of S.T., O.T.H., G.T.H. and M.L.T. · filed 2004-02-05(1)(E)

Barbara could not take care of M.L.T., and the child would be left unattended in her care upon her release from the hospital and subject to the same environment as the other children. The evidence is legally and factually sufficient to support a finding that appellant engaged in conduct that endangered the physical and emotional well-being of M.L.T., as well as that of his other three children.

Section 161.001(1)(E) requires clear and convincing evidence that a parent’s conduct, or the conduct of someone with whom the parent knowingly placed a child, endangered the child’s physical or emotional well-being.

in the Interest of J. W. M., Jr. and L. P. M., Children · filed 2004-03-29(1)(E)

The record contains sufficient uncontroverted, clear and convincing evidence, much of it from appellant’s own testimony, for the court to have reasonably formed a firm belief or conviction that appellant engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered the physical and emotional well-being of the children.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent engaged in conduct, or knowingly placed children with people whose conduct, endangered the children’s physical or emotional well-being.

In the Interest of J.W.M. · filed 2004-04-29(1)(E)

The record contains sufficient uncontro-verted, clear and convincing evidence, much of it fi'om appellant’s own testimony, for the court to have reasonably formed a firm belief or conviction that appellant engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered the physical and emotional well-being of the children.

Section 161.001(1)(E) provides a ground for termination when clear and convincing evidence shows that a parent engaged in conduct, or knowingly placed children with people whose conduct, endangered the children's physical or emotional well-being.

Clayton Edward Davis, Jr. v. State · filed 2004-05-14(1)(E)

The record contains sufficient uncontroverted, clear and convincing evidence, much of it from appellant's own testimony, for the court to have reasonably formed a firm belief or conviction that appellant engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered the physical and emotional well-being of the children.

Section 161.001(1)(E) permits termination on clear and convincing evidence that a parent engaged in endangering conduct or knowingly placed children with someone who did.

in the Interest of R.S., J.S., and A.L. · filed 2004-07-01(1)(E)

Section 161.001(1)(E) of the Texas Family Code allows the trial court to terminate the parent-child relationship if the court finds by clear and convincing evidence that the parent had engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered the physical or emotional well-being of the children. Here, the State established this ground by clear and convincing evidence.

Section 161.001(1)(E) provides a ground for termination when a parent engages in conduct, or knowingly places a child with someone whose conduct, endangers the child's physical or emotional well being.

In Re AJL · filed 2004-04-29(1)(E)

After a review of the evidence, we hold that the physical symptoms of abuse on the children, appellant's admitted drug abuse, her criminal history and incarceration, the expert witness testimony regarding A.J.L., appellant's long history with DFPS and KCPS, and her continuing course of violent conduct are all sufficient to support the jury's finding that appellant engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered their physical or emotional well being.

Section 161.001(1)(E) permits termination when sufficient evidence shows that a parent engaged in conduct, or knowingly placed a child with someone who engaged in conduct, that endangered the child’s physical or emotional well being.

in the Interest of A.J.L. and C.R.L., Children · filed 2004-04-29(1)(E)

After a review of the evidence, we hold that the physical symptoms of abuse on the children, appellant’s admitted drug abuse, her criminal history and incarceration, the expert witness testimony regarding A.J.L., appellant’s long history with DFPS and KCPS, and her continuing course of violent conduct are all sufficient to support the jury’s finding that appellant engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered their physical or emotional well being.

Section 161.001(1)(E) permits termination when a sustained course of parental conduct endangers a child's physical well-being, including repeated failure to maintain a safe home.

Parie v. Texas Department of Protective and Regulatory Services · filed 2004-07-01(1)(E)

Evidence of this "course of conduct" is legally and factually sufficient to find that Parie engaged in conduct that endangered T.K.P.'s physical well-being.

Under section 161.001(1)(E), a parent's continuing criminal conduct can endanger a child's physical and emotional well-being by depriving the child of contact with the parent.

Karl v. Texas Department of Protective and Regulatory Services · filed 2004-07-15(1)(E)

From this evidence, a fact-finder could have reasonably formed a firm belief that Karl's course of criminal conduct endangers his infant son's emotional well-being, if nothing else, by depriving the child of contact with his parent.

Section 161.001(1)(E) treats a parent’s conduct as endangering a child when it exposes the child to loss or injury, even if the conduct is directed at another child and the parent’s child suffers no actual injury.

in the Interest of S.F., M.F., C.F., Children · filed 2004-07-23(1)(E)

“Endangerment,” as used in subparagraph (1)(E) of Section 161.001, means exposure to loss or injury. It is not a requirement that the conduct be directed at the parent’s child, or that the child actually suffer injury.

Section 161.001(1)(E) requires a voluntary, deliberate, and conscious course of parental conduct that endangers a child; a single act or omission is insufficient.

in the Interest of M.N.G. · filed 2004-08-19(1)(E)

Termination under section 161.001(1)(E) must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required.

Section 161.001(1)(E) permits termination when a parent follows a voluntary, deliberate course of conduct that endangers a child; courts may consider conduct before the child's birth.

In Re MNG · filed 2004-09-16(1)(E)

Termination under section 161.001(1)(E) must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required. ... To determine whether termination is necessary, courts may look to parental conduct both before and after the child's birth. ... Based upon this evidence, we hold that the evidence is legally sufficient to support the jury's finding that appellant engaged in conduct that endangered M.N.G.'s physical or emotional well-being.

A parent's failure to protect children after learning of sexual abuse can constitute a course of conduct that endangers their well-being under subsection (1)(E).

In Re LC · filed 2004-09-16(1)(E)

James' failure to protect the children adequately, even after having been told about the sexual abuse, represents a course of conduct which endangered the well-being of the children.

Section 161.001(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being, including drug use during pregnancy.

In Re SMLD · filed 2004-09-23(1)(E)

The record contains sufficient clear and convincing evidence for the court to have reasonably formed a firm belief or conviction that Carter engaged in conduct that endangered the physical and emotional well-being of her child, and is thus legally sufficient to support that finding. Tex. Fam.Code Ann. § 161.001(1)(E).

Termination for endangering conduct requires a voluntary, deliberate, and conscious course of conduct, rather than a single act or omission.

in the Interest of K. L., J. H., C. J. L., S. F. L. and I. J. L., Children · filed 2004-10-19(1)(E)

Additionally, termination under section 161.001(1)(E) must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required.

A parent’s repeated refusal to believe a child’s sexual abuse allegations can constitute endangering conduct under section 161.001(1)(E) when it leaves the child without a safe and stable environment.

in the Interest of K.M., a Child · filed 2004-11-12(1)(E)

The evidence established that by her conduct in continuing to disbelieve K.M.’s allegations, Yama is unable to provide a safe and stable environment for K.M. Applying the appropriate standards of review, we find that there is factually sufficient evidence to support termination of Yama’s parental rights based upon the grounds listed in section 161.001(1)(E), that Yama knowingly engaged in conduct which endangered K.M.’s physical or emotional well-being.

Section 161.001(1)(E) requires a voluntary, deliberate, and conscious course of parental conduct; a single act or omission is insufficient.

in the Interest of J.H., a Child · filed 2004-11-18(1)(E)

Additionally, termination under section 161.001(1)(E) must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required.

Section 161.001(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being.

In the Interest of J.W. · filed 2004-12-02(1)(E)

Viewing all the evidence in a neutral light, both in favor of and contrary to the trial court’s judgment, we conclude that there is factually sufficient evidence to support the jury’s finding that Smith engaged in a course of conduct endangering J.W.’s physical and emotional well-being.

Section 161.001(1)(E) permits termination when a parent's violent conduct toward one child and the other parent endangers the other children.

In Re JC · filed 2004-12-07(1)(E)

The violent acts and behavior directed at one child and at the child's mother in the presence of the other children satisfy the requirement of Section 161.001(1)(E).

Section 161.001(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being, including violence toward another child or the other parent.

in the Interest of J.C., G.C., I.C., and T.C., Children · filed 2004-12-07(1)(E)

The violent acts and behavior directed at one child and at the child’s mother in the presence of the other children satisfy the requirement of Section 161.001(1)(E).

Section 161.001(1)(E) permits termination on the ground of endangerment by conduct when the evidence supports a finding that a parent knowingly exposed children to conduct that endangered their physical or emotional well-being.

in the Interest of T.N. and M.N., Children · filed 2004-07-22(1)(E)

we hold that the evidence is factually sufficient to support the jury findings on endangerment by conduct.

Section 161.001(1)(E) permits termination when a parent's voluntary, deliberate, and conscious course of conduct endangers a child's physical or emotional well-being.

Perez v. TEX. DEPT. OF PRO. & REG. SERVICES · filed 2004-08-05(1)(E)

Additionally, termination under subsection (E) must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required. ... Likewise, the evidence is factually sufficient to support the finding that Perez had engaged in conduct or had knowingly placed the children with persons who engaged in conduct that endangered their physical or emotional well-being.

Section 161.001(1)(E) requires a voluntary, deliberate, and conscious course of parental conduct that endangers a child; a single act or omission is insufficient.

Antero Perez AKA Antero P. Gonzalez and Patricia Saenz v. Texas Department of Protective and Regulatory Services · filed 2004-08-05(1)(E)

Additionally, termination under subsection (E) must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required.

Section 161.001(1)(E) permits termination when a parent's course of conduct, including failures to act, endangers a child's physical or emotional well-being.

Castaneda v. Texas Department of Protective & Regulatory Services · filed 2004-08-31(1)(E)

Applying the appropriate standard of review, the evidence is both legally and factually sufficient to support a finding of endangerment under subsection (E), which includes both acts and omissions.

Section 161.001(1)(E) permits termination when a parent’s conduct, or knowing placement of a child with others, endangers the child’s physical or emotional well-being.

in the Interest of B. S. W. · filed 2004-12-23(1)(E)

Based on our review of the evidence, we find that it is legally and factually sufficient to support the trial court’s finding of endangerment.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent engaged in conduct endangering a child's physical or emotional well-being.

in the Interest of H.D.H. and C.M.H. · filed 2004-12-30(1)(E)

Accordingly, we find the evidence is such that a factfinder could reasonably form a firm conviction that Horton engaged in conduct which endangered the physical or emotional well-being of the children.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent engaged in conduct endangering a child's physical or emotional well-being.

In Re AAT · filed 2005-04-26(1)(E)

The evidence as set out above provides clear and convincing proof that both parents engaged in conduct which endangered the physical or emotional well-being of the children.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent engaged in conduct endangering a child’s physical or emotional well-being.

in the Interest of A.A.T., L.L.T., A.C., W.L.C., Jr., Children · filed 2005-04-26(1)(E)

The evidence as set out above provides clear and convincing proof that both parents engaged in conduct which endangered the physical or emotional well-being of the children.

Section 161.001(1)(E) permits termination when a parent pursues a course of conduct that endangers a child, without proof that the child was the focus of the conduct or was actually harmed.

in the Interest of S.D.S., G.R.R., J.R.R. and E.M.R., Children · filed 2005-05-03(1)(E)

To satisfy that ground, one need not prove that the children were the focus of the conduct or actually harmed by it. In re C.J.F., 134 S.W.3d 343, 351 (Tex. App.-Amarillo 2003, pet. denied). Rather, it is enough to simply show that the parent pursued a course of conduct having the effect of endangering the child.

Section 161.001(1)(E) permits termination for conduct that endangers a child’s physical or emotional well-being; delaying necessary medical treatment can support that ground.

in the Interest of G.G. and J.G., Children · filed 2005-05-19(1)(E)

Based on our review of the entire record, we conclude that the trial court could reasonably form a belief or conviction that appellant engaged in conduct that endangered her children’s physical or emotional well-being, and therefore, we hold that the evidence is factually sufficient to support the trial court’s finding. See Tex. Fam. Code Ann. § 161.001(1)(E).

Section 161.001(1)(E) provides a ground for termination when clear and convincing evidence shows that a parent’s conduct endangered a child’s physical or emotional well-being.

In the Interest of S.E.W. · filed 2005-05-19(1)(E)

Based on this and other evidence in the record, viewed in the light most favorable to the findings, the jury could reasonably form a firm belief or conviction that Father “engaged in conduct or knowingly placed the child[ren] with persons who engaged in conduct which endangers the physical or emotional well-being of the child[ren].” Tex. Fam.Code Ann. § 161.001(1)(E). We conclude the evidence is legally sufficient to support the jury’s finding.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent’s course of conduct endangered a child’s physical or emotional well-being.

in the Interest of C.C., C.C., C.C., C.C., and K.B., Children · filed 2005-05-26(1)(E)

Applying the appropriate standard of review, we hold that the evidence is such that a trier of fact could reasonably form a firm belief or conviction that Appellants knowingly engaged in conduct that endangered C.C.(1)’s, C.C.(2)’s, C.C.(3)’s, C.C.(4)’s, and K.B.’s physical or emotional well-being. Consequently, we hold that there is factually sufficient evidence to support the termination of Lynetta H.’s and Marcell B.’s parental rights based upon that ground.

Subsection (1)(E) allows an endangerment finding based on a parent’s conduct toward other children, including conduct before the child at issue was born.

In the Interest of S.P. · filed 2005-05-26(1)(E)

We have consistently held that a parent’s conduct both before and after a child is born is relevant to the determination of whether the conduct endangers the child’s physical or emotional well-being. ... Thus we reject Mother’s argument that the endangerment finding as to M.G. can only be supported by evidence of her conduct toward that child, and look at all the evidence in the record under the appropriate standard of review.

Section 161.001(1)(E) permits termination based on a parent’s own endangering conduct or the parent’s knowing exposure of the child to the other parent’s endangering conduct.

in the Interest of K. M.H · filed 2005-07-14(1)(E)

The allegations permitted termination based not only on each parent’s own conduct endangering K.M.H., but upon each parent’s knowing exposure of K.M.H. to the other parent’s endangering conduct.

Section 161.001(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being; persistent unsanitary conditions can support that finding, including for a later-born child.

In Re WRE · filed 2005-07-18(1)(E)

Because we conclude that the evidence is both legally and factually sufficient to support the jury's findings under subsection (E), and a finding as to any one of the acts or omissions enumerated in section 161.001(1) is sufficient to support termination, we need not address Elrod's other issues.

Section 161.001(1)(E) provides a ground for termination when clear and convincing evidence shows that a parent’s conduct, or the conduct of someone with whom the parent knowingly placed a child, endangered the child’s physical or emotional well-being.

in the Interest of D.T.D. and K.C.H., Children · filed 2005-08-04(1)(E)

Termination based on section 161.001(E) is proper if clear and convincing evidence shows that the parent engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered the children’s physical or emotional well-being. ... Accordingly, the evidence is legally and factually sufficient to support termination of Augustine’s parental rights under section 161.001(E).

Section 161.001(1)(E) permits consideration of a parent’s conduct before a child’s birth and conduct toward other children when deciding whether the parent endangered that child.

In Re SP · filed 2005-08-05(1)(E)

We have consistently held that a parent's conduct both before and after a child is born is relevant to the determination of whether the conduct endangers the child's physical or emotional well-being. ... Thus we reject Mother's argument that the endangerment finding as to M.G. can only be supported by evidence of her conduct toward that child, and look at all the evidence in the record under the appropriate standard of review.

Section 161.001(1)(E) permits termination based on clear and convincing evidence of parental conduct, including failures to act, that endangers a child's physical or emotional well-being.

In Re SEW · filed 2005-08-19(1)(E)

Based on this and other evidence in the record, viewed in the light most favorable to the findings, the jury could reasonably form a firm belief or conviction that Father "engaged in conduct or knowingly placed the child[ren] with persons who engaged in conduct which endangers the physical or emotional well-being of the child[ren]." Tex. Fam.Code Ann. § 161.001(1)(E). We conclude the evidence is legally sufficient to support the jury's finding.

A parent's course of drug use and negligent supervision can establish endangerment under subsection (1)(E) without proof that the child was actually injured.

Vasquez v. Texas Department of Protective & Regulatory Services · filed 2005-12-30(1)(E)

Despite there being no direct evidence of appellant's drug use or neglect actually injuring Z.M., TDPRS presented evidence that appellant engaged in a course of conduct that endangered Z.M.'s physical and emotional well-being.

Section 161.001(1)(E) permits termination when a parent’s course of drug use and inadequate supervision endangers a child, even without proof of actual injury.

Vasquez v. Department of Family and Protective Services · filed 2005-12-30(1)(E)

Despite there being no direct evidence of appellant’s drug use or neglect actually injuring Z.M., TDPRS presented evidence that appellant engaged in a course of conduct that endangered Z.M.’s physical and emotional well-being. ... We hold that the evidence is legally sufficient to show that appellant endangered Z.M.

Section 161.001(1)(E) requires a voluntary course of parental conduct that endangers a child’s physical or emotional well-being; a single act or omission is insufficient.

in the Interest of H.H. and R.H., Children · filed 2006-01-26(1)(E)

We hold that the evidence is both legally and factually sufficient to support a jury’s finding of endangerment under section 161.001(1)(E).

Section 161.001(1)(E) permits a court to consider a parent's conduct before and after a child's birth when deciding whether that conduct endangered the child.

Wyatt v. Department of Family and Protective Services · filed 2006-02-16(1)(E)

However, a court may consider a parent’s conduct both before and after a child’s birth as grounds for termination. ... In this case, appellant showed a pattern of medical neglect with her first two children as well as a pattern of angry disturbances. A factfinder could have reasonably believed that appellant’s conduct endangered the physical and emotional well-being of A.W.

Section 161.001(1)(E) permits termination for a parent's course of conduct that endangers a child, even if the child was not the focus of the conduct or actually harmed.

in the Interest of P.M., a Child · filed 2006-02-22(1)(E)

To satisfy that ground, the complainant need not prove that the child was the focus of the conduct or actually harmed by it.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent’s conduct, or the conduct of someone with whom the parent knowingly placed a child, endangered the child’s physical or emotional well-being.

in the Interest of S.K.D.C., T.K.B., and I.J.W., Children · filed 2006-03-29(1)(E)

We hold that the evidence is sufficient to show that Lawanda engaged in conduct or knowingly placed S.K.D.C, T.K.B., and I.J.W. with persons who engaged in conduct that endangered their physical or emotional well-being.

Section 161.001(1)(E) permits termination when a parent's conduct endangers a child's physical or emotional well-being; sexual assault of a stepchild can support that finding.

In the Interest of Baby Boy R. · filed 2006-05-22(1)(E)

We conclude that a reasonable trier of fact could have formed a firm belief or conviction that Gidney, having pleaded guilty to aggravated sexual assault of his stepchild, engaged in conduct which had the effect of endangering the child’s physical or emotional well-being.

Section 161.001(1)(E) requires a parent to act knowingly when placing children with a person whose conduct endangers them.

in the Interest of T.R.E., D.E., S.L.R., and K.J.P. · filed 2005-12-08(1)(E)

To the extent the Department claims Jacquelyn failed to protect the children from Robert's endangering conduct, her act of placing the children with the endangering person must be made knowingly. See Tex. Fam. Code Ann. § 161.001(1)(E) (Vernon Supp. 2005). ... We hold the evidence is both legally and factually sufficient evidence to support the trial court's finding of conduct endangerment.

Section 161.001(1)(E) permits termination for conduct endangering a child’s physical or emotional well-being, including conduct before the child’s birth.

Wyatt v. Department of Family & Protective Services · filed 2006-02-16(1)(E)

However, a court may consider a parent’s conduct both before and after a child’s birth as grounds for termination. ... A factfinder could have reasonably believed that appellant’s conduct endangered the physical and emotional well-being of A.W.

Section 161.001(1)(E) permits an endangerment finding without proof that parental conduct caused an actual injury if the conduct exposed the child to injury or jeopardized the child's well-being.

Rochelle v. Department of Family and Protective Services · filed 2006-02-09(1)(E)

Thus, even though no causal connection was established between appellant’s actions and an actual injury to the twins, the trial court could have inferred that appellant’s conduct exposed the twins to injury and placed them in jeopardy, i.e. endangered the twins’ physical well-being.

Sexual abuse of another child in the home can establish endangerment under § 161.001(1)(E).

In the Interest of E.A.K. · filed 2006-02-28(1)(E)

This properly considered evidence supports the conclusion that Mustofa molested J.J. while she was living in his home and under his care and while E.A.K. was also present in the home. Consequently, we find that it constituted legally sufficient evidence of endangerment to E.A.K. to support the jury’s finding of termination.

Section 161.001(1)(E) permits termination when a parent’s course of conduct endangers a child, including when past abuse of other children supports an inference of future harm.

Reyna v. Department of Family and Protective Services · filed 2006-04-27(1)(E)

From appellant’s abuse of her three oldest daughters and her subsequent assault on a police officer, the trial court could have inferred that (1) appellant had engaged in course of conduct that endangered physical or emotional well-being of A.E.R., (2) appellant would continue her pattern of abusive behavior, and (3) A.E.R. would face abuse if placed in appellant’s care.

Section 161.001(1)(E) permits termination for a parent’s course of conduct that endangers a child’s physical or emotional well-being without requiring proof of actual injury.

Clawson v. Texas Department of Protective and Regulatory Services · filed 2006-07-21(1)(E)

Section 161.001(1)(E) focuses on the risk of both physical and emotional injury and does not require any actual injury to the child, let alone serious physical injury. It does, however, require that the parent’s behavior constitutes a course of conduct endangering the child.

Section 161.001(1)(E) permits termination when a parent's prenatal cocaine use endangers the child's physical or emotional well-being.

Kovey Amanette Cervantes-Peterson A/K/A Kovey Peterson Cervantes A/K/A Kovey Turner Cervantes v. Department of Family an · filed 2006-08-03(1)(E)

Accordingly, we hold that the evidence is legally sufficient to support the trial court’s finding under section 161.001(1)(E) that Cervantes engaged in conduct that endangered the physical and emotional well-being of J.M.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent’s conduct, or the conduct of someone with whom the parent knowingly placed the child, endangered the child’s physical or emotional well-being.

in the Interest of D.D.S., a Child · filed 2006-08-10(1)(E)

Accordingly, the evidence is legally and factually sufficient to support termination of appellant’s parental rights under section 161.001(E).

A parent’s inability to oversee children’s safety because of disability and required medication can support a finding of endangering conduct under § 161.001(1)(E).

In the Interest of R.B. · filed 2006-08-22(1)(E)

We conclude the evidence is clearly legally sufficient to support a finding that Mother engaged in conduct which endangered the well-being of the children. The evidence of Mother’s disability, her required medication, and her resulting inability to oversee the safety of the children were well established by the record.

Repeated criminal conduct that leaves a parent incarcerated and absent from a child’s life can support termination for endangering the child’s emotional well-being.

Curtis v. State · filed 2006-08-31(1)(E)

Having carefully reviewed the evidence, we hold that the trial court could have formed a firm belief or conviction that Phillip had engaged in conduct that endangered B.P.W.’s emotional well-being.

Section 161.001 permits termination when clear and convincing evidence shows that a parent engaged in conduct endangering a child and that termination is in the child's best interest.

In Re Rb · filed 2006-09-18(1)(E)

A court may order involuntary termination of a parent's rights only if the court finds that: (1) the parent has committed a predicate act or omission harmful to the child, and (2) termination is in the best interest of the child. TEX. FAM.CODE ANN. § 161.001 (Vernon 2002). ... We conclude the evidence is clearly legally sufficient to support a finding that Mother engaged in conduct which endangered the well-being of the children. ... Finally, we conclude the evidence is legally and factually sufficient to support the jury's finding that termination was in the children's best interest.

Section 161.001(1)(E) allows an endangerment finding based on a parent's course of conduct that jeopardizes a child's well-being.

In Re AJH · filed 2006-09-28(1)(E)

Given the circumstances of both Appellant and the child, and based on the applicable standard of review, [8] we hold that the evidence is factually sufficient to support the finding that Appellant engaged in conduct that endangered A.J.H.'s well-being.

Section 161.001(1)(E) permits termination when a parent’s course of conduct endangers a child’s well-being.

in the Interest of A.J.H., a Child · filed 2006-09-28(1)(E)

Given the circumstances of both Appellant and the child, and based on the applicable standard of review, ... we hold that the evidence is factually sufficient to support the finding that Appellant engaged in conduct that endangered AJ.H.’s well-being.

Section 161.001(1)(E) permits termination when a parent's conduct, including omissions, endangers a child's physical or emotional well-being.

In Re CMB · filed 2006-10-27(1)(E)

To terminate a parent's rights under subsection (E) of section 161.001, the evidence must show the parent engaged in conduct or knowingly placed the child with persons who engaged in conduct that endangered the child's physical or emotional well being. ... We further conclude that, based on the evidence in this case, a reasonable trier of fact could conclude by clear and convincing evidence that appellant engaged in conduct that endangered her children.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent engaged in conduct endangering a child's physical or emotional well-being.

In Re SB · filed 2006-11-02(1)(E)

Based on our review of the entire record, we conclude that a factfinder could reasonably form a firm belief or conviction that appellant engaged in conduct that endangered the physical or emotional well-being of S.B. and Y.B., and therefore, we hold that the evidence is legally and factually sufficient to support the trial court's finding.

Section 161.001(1)(E) covers parental conduct that endangers a child’s physical or emotional well-being, including violence in the home and drug use while caring for the child.

in the Interest of S.B. and Y.B., Minor Children · filed 2006-11-02(1)(E)

Based on our review of the entire record, we conclude that a factfinder could reasonably form a firm belief or conviction that appellant engaged in conduct that endangered the physical or emotional well-being of S.B. and Y.B., and therefore, we hold that the evidence is legally and factually sufficient to support the trial court’s finding.

Section 161.001(1)(E) permits termination when a parent's course of conduct endangers a child's well-being.

Willie A. Milton, 561014 v. Doug Dretke, Director, TDCJ-CID · filed 2006-09-28(1)(E)

Given the circumstances of both Appellant and the child, and based on the applicable standard of review, (footnote: 8) we hold that the evidence is factually sufficient to support the finding that Appellant engaged in conduct that endangered A.J.H.’s well-being.

Section 161.001(1)(E) permits termination for a parent's endangering course of conduct even if the conduct was not directed at the child, caused no injury, or occurred before the child's birth.

in the Interest of C.S.C., a Child · filed 2006-11-30(1)(E)

However, endangering acts need not be directed at the child or cause actual injury or threat of injury to the child, and as mentioned above, endangerment may include what a parent does both before and after the birth of a child.

Section 161.001(1)(E) permits termination for endangering conduct when evidence of a parent’s physical abuse and drug use supports a firm belief that the parent endangered the children.

in the Interest of H.J.A., a Minor Child · filed 2006-12-14(1)(E)

Thus, the evidence was legally sufficient to support the trial court’s finding under section 161.001(1)(E) of the family code.

Under subsection (1)(E), a parent's conduct that endangers a child's physical or emotional well-being can support termination when proved by clear and convincing evidence.

in the Interest of H.G., a Child · filed 2007-01-11(1)(E)

Based on our review of the entire record, we conclude that a factfinder could reasonably form a firm belief or conviction that appellant engaged in conduct that endangered the physical or emotional well-being of H.G., and therefore, we hold that the evidence is factually sufficient to support the jury’s finding.

Section 161.001(1)(E) permits termination when a parent's continuing course of conduct, including drug use, endangers the child's well-being.

in the Interest of M. L. M., a Child · filed 2007-01-12(1)(E)

The evidence is sufficient to support a firm conviction or belief that appellant engaged in conduct that endangered MLM's well-being, and thus is legally and factually sufficient to support the court's finding.

Section 161.001(1)(E) permits termination for a parent's own endangering conduct even if the parent did not know the conduct was dangerous.

in the Interest of D.R., C.D., Jr., Q.R., E.R., and Y.R., Children · filed 2007-01-25(1)(E)

The parent need not know that his or her own conduct is dangerous for a termination order pursuant to section 161.001(1)(E) to be proper.

Section 161.001(1)(E) allows a parent’s endangering conduct toward one child to support termination of parental rights to another child, even if that child was not present or injured.

in the Interest of B.C. and O.C., Children · filed 2007-03-29(1)(E)

This argument fails because a parent’s conduct need not be directed at the child who is the subject of the termination proceedings or even result in injury to the child to constitute endangerment.

Section 161.001(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being; imprisonment may be considered as part of that course of conduct.

In Re NSG · filed 2007-09-12(1)(E)

On the other hand, if the evidence, which includes imprisonment, shows a course of conduct which has the effect of endangering the physical or emotional well-being of the child, a finding under Section 161.001(1)(E) is supportable.

Section 161.001(1)(E) permits termination when a parent's course of conduct, including conduct resulting in imprisonment, endangers a child's physical or emotional well-being.

In the Interest of N.S.G., a Minor Child · filed 2007-09-12(1)(E)

On the other hand, if the evidence, which includes imprisonment, shows a course of conduct which has the effect of endangering the physical or emotional well-being of the child, a finding under Section 161.001(1)(E) is supportable.

Section 161.001(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being; continued drug use and related conduct can support that finding.

In the Interest of S.K.A., M.A., and SA., Minor Children · filed 2007-10-17(1)(E)

The evidence is legally and factually sufficient to support the predicate finding of conduct endangerment.

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent’s conduct endangered a child’s physical or emotional well-being.

in the Interest of J.A.B., a Child · filed 2007-10-18(1)(E)

Having carefully considered the evidence and applying the appropriate standards of review, (footnote: 32) we hold that the trial court could have reasonably formed a firm belief or conviction that Jerri engaged in conduct that endangered the physical or emotional well-being of J.A.B., and the evidence was legally and factually sufficient to support the court’s finding under family code section 161.001(1)(E).

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent's conduct endangers a child's physical or emotional well-being.

In Re SKA · filed 2007-11-06(1)(E)

The evidence is legally and factually sufficient to support the predicate finding of conduct endangerment. Having found legally and factually sufficient evidence of Chad's conduct endangering the children, we need not assess the sufficiency of the evidence on the other predicate grounds for termination.

Section 161.001(1)(E) does not require proof that the children were the focus of the endangering conduct or were actually harmed by it.

in the Interest of T.U., K.U., and K.U., Children · filed 2007-11-08(1)(E)

To satisfy it, the State need not have proved that the children at issue here were the focus of the conduct or that they were actually harmed by it.

A parent's abuse of controlled substances during pregnancy can support a child endangerment finding under § 161.001(1)(E).

In Re As · filed 2007-10-11(1)(E)

Evidence that Perkins abused controlled substances while pregnant will support a finding of child endangerment.

Section 161.001(1)(E) allows controlled-substance abuse during pregnancy to support a finding of child endangerment.

in the Interest of A.S. · filed 2007-10-11(1)(E)

Evidence that Perkins abused controlled substances while pregnant will support a finding of child endangerment.

Section 161.001(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being.

in the Interest of M.R. and W.M., Children · filed 2007-12-13(1)(E)

Based on our review of the entire record, we conclude that a factfinder could reasonably form a firm belief or conviction that W.P.M. engaged in conduct and knowingly placed W.M. with persons who engaged in conduct which endangered the physical or emotional well-being of W.M. Therefore, we hold that the evidence is factually sufficient to support the trial court’s findings under section 161.001(1)(E).

Section 161.001(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being.

in the Interest of J.E.H., a Child · filed 2008-02-21(1)(E)

Thus, the evidence was factually sufficient to support the court’s finding under family code section 161.001(1)(E).

Section 161.001(1)(E) requires a conscious course of endangering conduct; a single use of marijuana during pregnancy, standing alone, is insufficient.

in the Interest of A.S., D.S. and L.A.S · filed 2008-03-04(1)(E)

While unquestionably, an exercise of poor judgment, Veronica’s use of marijuana on a single occasion, standing alone, does not rise to the level of a conscious course of conduct.

Subsection (1)(E) permits termination when a parent's voluntary, deliberate course of conduct endangers a child's well-being; actual injury is unnecessary.

in the Interest of L.A.W., a Minor Child · filed 2008-03-20(1)(E)

Based on the applicable standards of review, (footnote: 16) we hold that the evidence is legally and factually sufficient to support the trial court’s finding as to Kenneth’s endangering course of conduct.

Section 161.001(1)(E) allows termination based on a deliberate course of parental conduct that endangers a child’s physical or emotional well-being.

in the Interest of D.F., a Child · filed 2008-03-27(1)(E)

Thus, when viewing all the evidence in the light most favorable to the judgment, we hold that the evidence was legally sufficient to support the court’s finding that David has engaged in a deliberate course of conduct that has endangered D.F.’s well-being.

Section 161.001(1)(E)'s endangerment ground can be supported by a parent's criminal conduct, including involvement with marihuana, when it endangers the child's physical or emotional well-being.

In Re ST · filed 2008-05-28(1)(E)

The evidence of Donald's criminal conduct, and in particular his involvement with marihuana, is such that the trial court as factfinder could have reasonably formed a firm belief or conviction that Donald engaged in conduct which endangered S.T.'s physical and emotional well-being.

Section 161.001(1)(E) permits termination when a parent’s acts or omissions form a course of conduct that endangers a child’s physical or emotional well-being.

in the Interest of L.E.W., a Child · filed 2007-12-13(1)(E)

Accordingly, we hold that the evidence is legally sufficient to support the trial court’s finding of endangerment under subsection (E), which includes both acts and omissions.

Section 161.001(1)(E) permits termination when a parent’s course of conduct endangers a child, even if the conduct is not directed toward the child.

In the Interest of S.T. · filed 2008-05-28(1)(E)

Donald contends in his second point that the evidence is factually insufficient to support the court’s finding under section 161.001(1)(E) that he engaged in conduct which endangered S.T.’s physical or emotional well-being. ... A parent may be found to have engaged in conduct which endangers a child even if that conduct is not directed toward the child. ... The evidence of Donald’s criminal conduct, and in particular his involvement with marihuana, is such that the trial court as factfinder could have reasonably formed a firm belief or conviction that Donald engaged in conduct which endangered S.T.’s physical and emotional well-being.

Section 161.001(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being.

in the Interest of M.B., M.M.A., M.G.A., M.R.A., and M.W.A., Jr., Children · filed 2008-07-31(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to support the trial court’s findings under subsection 161.001(1)(E).

Section 161.001(1)(E) permits termination when clear and convincing evidence shows that a parent’s conduct endangered a child’s physical or emotional well-being.

in the Interest of T. H., T. H., and D. H., Children · filed 2008-08-12(1)(E)

Viewing the evidence before us as a whole, we find there was sufficient clear and convincing evidence to support the trial court’s finding that Julie engaged in conduct or knowingly placed the children with persons who engaged in conduct which endangered the physical or emotional well-being of her children.

Section 161.001(1)(E) requires a conscious course of endangering conduct; a single use of marijuana during pregnancy does not suffice.

In Re As · filed 2008-08-26(1)(E)

While unquestionably, an exercise of poor judgment, Veronica's use of marijuana on a single occasion, standing alone, does not rise to the level of a conscious course of conduct.

Subsection (1)(E) requires a voluntary, deliberate course of conduct that endangers a child's physical or emotional well-being; repeated domestic violence can satisfy that requirement.

In Re JJS · filed 2008-10-22(1)(E)

Termination under subsection 161.001(1)(E) must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required. ... Having reviewed the entire record, we find the evidence of Laura's conduct is such that the trial court as factfinder could have reasonably formed a firm belief or conviction that Laura engaged in conduct which endangered the physical and emotional well-being of her children.

A parent’s conduct exposing children to domestic violence can support a finding of endangerment under subsection (1)(E).

in the Interest of J.J.S., D.D.S., and L.S., Children · filed 2008-10-22(1)(E)

Having reviewed the entire record, we find the evidence of Laura’s conduct is such that the trial court as factfinder could have reasonably formed a firm belief or conviction that Laura engaged in conduct which endangered the physical and emotional well-being of her children.

Section 161.001(1)(E) permits termination when a parent's conduct endangers a child's physical or emotional well-being.

Weaver v. State · filed 2008-11-12(1)(E)

The evidence is legally and factually sufficient to support the predicate finding of conduct endangerment.

Section 161.001(1)(E) permits an endangerment finding based on a parent’s course of drug use and recent criminal conduct.

in the Interest of L.D.K., M.L.P., S.D.P. and D.E.P. · filed 2008-07-31(1)(E)

Further, when considering the entire record, we hold that a fact-finder could reasonably form a firm conviction or belief that Michael violated section 161.001(1)(E).

Section 161.001(1)(E) permits termination for a parent’s voluntary, deliberate, and conscious course of conduct that endangers a child, even if the child suffers no actual injury.

in the Interest of Z.D., a Child · filed 2008-09-25(1)(E)

We hold that the evidence is legally and factually sufficient to support the trial court’s finding under section 161.001(1)(E).

Section 161.001(1)(E) requires a voluntary, deliberate, and conscious course of parental conduct that endangers a child’s physical or emotional well-being.

in the Interest of M.C, N.L., and D.L., Children · filed 2008-10-09(1)(E)

Under subsection (E), the relevant inquiry is whether evidence exists that the endangerment of the child’s physical or emotional well-being was the direct result of the parent’s conduct, including acts, omissions, and failures to act, and it must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required. ... Therefore, we conclude that the evidence was both legally and factually sufficient to terminate E.C.’s parental rights based on the endangerment by conduct ground in subsection (E), and we overrule her second issue.

Section 161.001(1)(E) requires a voluntary, deliberate, and conscious course of parental conduct; a single act or omission is insufficient.

in the Interest of M.C., a Child · filed 2008-11-26(1)(E)

Termination under section 161.001(1)(E) must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required.

Repeated drug use before and after a child's birth or removal can establish an endangering course of conduct under subsection (1)(E).

in the Interest of R.R., a Child · filed 2008-12-11(1)(E)

Based on this evidence, Mary engaged in conduct that endangered the children's physical or emotional well-being. See Tex. Fam. Code Ann. § 161.001(1)(E). She exposed the children to injury and jeopardized their well-being, see Boyd , 727 S.W.2d at 533, through a voluntary, deliberate, and conscious course of conduct.

Section 161.001(1)(E) allows a parent’s acts and omissions to establish an endangering course of conduct.

Carpenter v. Texas Department of Family and Protective Services · filed 2008-12-31(1)(E)

The cause of the endangerment under subsection 161.001(1)(E) must be the parent’s conduct, evidenced not only by the parent’s acts but also by the parent’s omissions.

Section 161.001(1)(E) permits termination when a parent’s course of conduct endangers a child’s well-being, even if the child suffers no actual injury.

in the Interest of A.R., R.T.R., and L.R.M., Children · filed 2009-01-08(1)(E)

Accordingly, we conclude and hold, based on the appropriate standards of review, that the evidence is legally and factually sufficient to support termination under subsection E.

Subsection (1)(E) makes endangering conduct, or knowingly placing children with people who engage in it, a ground for termination when termination is also in the children’s best interest.

in the Interest of J.A.W., J.A.W., J.E.W., and J.A.W., Children · filed 2009-03-05(1)(E)

Therefore, the evidence is factually sufficient to support the trial court’s findings under section 161.001(1)(E).