Statute Annotations › Texas › Tex. Fam. Code Ann. § 161.001

Tex. Fam. Code Ann. § 161.001

Termination of the parent-child relationship: the cases that interpreted this section

Jurisdiction
Texas
Case notes
3,826
Cited in passing
943
Citing cases indexed
10,838
Case dates
1995–2026
Screened through
2026-06-24
Checked for later law changes
2026-10-19
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

4,769 citing cases reviewed of 10,838 in the citation index: 3,826 interpreted the section (annotated below), 943 cited it only in passing. Cases filed after 2026-06-24 may not have been reviewed yet.

Have a situation under Tex. Fam. Code Ann. § 161.001?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Best interest of the child

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; the court found that standard met here.

in the Interest of C.M.O. · filed 2015-06-24(b)(2)

Having examined the evidence under the applicable standards of review, we conclude the evidence pertaining to the trial court’s findings is both legally and factually sufficient for the trial court to have found by clear and convincing evidence that terminating L.J.’s parental rights to C.M.O. was in C.M.O.’s best interest.
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Section 161.001(2) requires a finding that termination is in the child’s best interest.

in the Interest of LG, a Child · filed 2015-07-08(2)

We hold the evidence is legally and factually sufficient to allow the trial court to find termination of Mother’s parental rights was in the best interest of L.G.
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Section 161.001(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of K.R.E.T. Children · filed 2015-07-22(2)

Having reviewed the evidence, we conclude it was legally and factually sufficient to support the trial court’s finding by clear and convincing evidence that termination of B.T.’s parental rights to K.R.E.T., C.R.A., D.S.T., and M.J.T. was in each child’s best interest.
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The court held the evidence legally sufficient to support a best-interest finding under § 161.001.

C. H. v. Texas Department of Family and Protective Services · filed 2015-07-23(2)

Viewing the above and other evidence in the light most favorable to the district court’s finding, we conclude that the evidence is legally sufficient to prove that termination of C.H.’s parental rights was in the best interest of the children.
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Section 161.001(2) requires the Department to prove by clear and convincing evidence that termination is in the child’s best interest, even when the parent has signed a mediated settlement agreement and an affidavit of relinquishment.

in the Interest of K.D., a Minor Child · filed 2015-07-29(2)

Stated differently, a mediated settlement agreement and an affidavit of relinquishment in a parental-rights termination case may be binding between the parties, but it does not eliminate the Department’s burden of proving by clear and convincing evidence under Section 161.001(2) that termination is in the child’s best interest or the trial court’s power to deny termination in the absence of such proof.
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Section 161.001(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

J. R. and L. R. v. Texas Department of Family and Protective Services · filed 2015-07-30(2)

Viewing the evidence related to these and the other Holley factors in the light most favorable to the jury’s finding, we conclude that the evidence is legally sufficient to prove that termination of Lena’s parental rights was in the children’s best interest. See Holley, 544 S.W.2d at 372. Having given due consideration to the disputed evidence in the case, we reach the same conclusion regarding the factual sufficiency of the evidence.
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Section 161.001(2) requires clear and convincing evidence that termination of parental rights is in the child’s best interest.

A. R. v. Texas Department of Family and Protective Services · filed 2015-08-12(2)

On this record, we conclude that the evidence is both legally and factually sufficient to support the trial court’s determination that there was clear and convincing evidence that termination was in B.R.’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of J.M.O., a Child · filed 2015-08-12(b)(2)

Reviewing the evidence under the two standards, we conclude the trial court could have formed a firm belief or conviction that terminating J.D.O.’s parental rights to J.M.O. was in J.M.O.’s best interest.
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Section 161.001(2) requires a best-interest finding supported by sufficient evidence, which the court found in this case.

in the Interest of A.R.R. and N.R.R. · filed 2015-08-19(2)

To terminate parental rights pursuant to section 161.001 of the Family Code, the Department has the burden to prove: (1) one of the predicate grounds in subsection 161.001(1); and (2) that termination is in the best interest of the child. ... Having reviewed the record, we hold the evidence is sufficient to support the trial court’s finding that termination was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; the finding is factually sufficient when the full record supports a firm belief or conviction despite disputed evidence.

in the Interest of M.M.-Y.P. · filed 2015-08-27(b)(2)

Viewing all of the evidence, disputed and undisputed, it is sufficient to produce a firm belief or conviction that termination of Mother’s parental rights was in Mary’s best interest. See TEX. FAM. CODE ANN. § 161.001(b)(2); In re J.F.C., 96 S.W.3d at 266. ... Accordingly, we hold that the evidence is factually sufficient to support the trial court’s finding that termination of Mother’s parental rights was in Mary’s best interest.
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Section 161.001(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of R.R., Jr. E.R.R. E.B.R. And J.S.R., Children · filed 2015-08-28(2)

We hold that, based on clear and convincing evidence presented at trial and the Holley factors, the trial court could reasonably have formed a firm belief or conviction that termination of the mother’s parental rights would be in the best interest of the children.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of A.A.M. and R.M.M., Children · filed 2015-09-09(2)

After reviewing the entire record, we conclude the State satisfied its burden to establish by clear and convincing evidence that termination of appellant’s parental rights to his two children is in the children’s best interest.
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Section 161.001(b)(2) requires sufficient evidence that termination is in the child’s best interest.

in the Interest of S.D. and I.D., Children · filed 2015-09-10(b)(2)

Applying the appropriate standards of review, we hold that legally and factually sufficient evidence supports the trial court’s finding that termination of the parent-child relationships between Mother and the children is in the children’s best interest.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of S.S.B. and R.D., III, Children · filed 2015-09-15(2)

Applying the applicable Holley factors to the evidence, we conclude that legally and factually sufficient evidence supports the trial court’s finding that termination of the father’s rights is in the best interest of R.D., III.
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Section 161.001(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of J.R.S. · filed 2015-09-23(2)

Having reviewed the evidence, we conclude it was legally and factually sufficient to support the trial court’s finding by clear and convincing evidence that termination of B.J.D.’s parental rights to J.R.S. was in J.R.S.’s best interests.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of K.H., S.W., and I.W., Children · filed 2015-10-15(b)(2)

Viewing all of the evidence in the light most favorable to the best-interest finding and considering the statutory and Holley factors, we hold that the trial court could have reasonably formed a firm conviction or belief that termination of the parent-child relationship between Father and Sonny and between Father and Irene was in the children’s best interest, and we therefore hold the evidence legally sufficient to support the jury’s best-interest finding.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest; continued drug use, domestic violence, and unsafe living conditions can support that finding.

in the Interest of A.M.Y., R.C.M., and E.J.M.Y., Children · filed 2015-10-21(2)

Termination of parental rights requires proof by clear and convincing evidence that the parent committed one of the acts or omissions listed in section 161.001(1)(A)-(T) of the Texas Family Code and that termination is in the child’s best interest. ... Considering the evidence under the appropriate standards of review, we conclude that the trial court could have formed a firm belief or conviction that terminating Frank’s parental rights was in the best interest of E.J.M.Y., and could have formed a firm belief or conviction that terminating Mary’s parental rights was in the best interest of A.M.Y., R.C.M., and E.J.M.Y.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

Interest of J.G.M., a Child · filed 2015-10-21(2)

We hold the evidence is legally and factually sufficient to allow the trial court to find termination of Father’s parental rights was in the best interest of J.G.M.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child's best interest, even when a statutory ground for termination is supported.

in the Interest of J.T., a Child · filed 2015-10-22(2)

Notwithstanding the sufficiency of the evidence to support termination under section 161.001(1), we must also find clear and convincing evidence that termination of the parent-child relationship was in the children's best interest. ... After reviewing the record, we agree with counsel's evaluations that there is clear and convincing evidence under the appropriate legal and factual sufficiency standards for the trial court to have determined that termination of the parent-child relationship was in the best interest of J.T. and M.K.
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Section 161.001(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

J. T. and P. T. v. Texas Department of Family and Protective Services · filed 2015-10-23(2)

Therefore, we conclude that the evidence was legally and factually sufficient to support the jury’s finding that the termination of Father’s and Mother’s parental rights is in the children’s best interest.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of D.G., K.G., H.M.G., Children · filed 2015-10-28(2)

To terminate parental rights, the fact-finder must find, by clear and convincing evidence, that the parent has engaged in at least one statutory ground for termination 3 and that termination is in the child’s best interest.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of C.F.N. · filed 2015-10-28(2)

A trial court may order termination of the parent-child relationship only if the court finds by clear and convincing evidence one or more statutory grounds for termination and that termination is in the child’s best interest. TEX. FAM. CODE § 161.001(1), (2); § 161.206(a). ... On this record, we conclude the evidence permits a reasonable factfinder to form a firm conviction and belief that termination of the parent/child relationship was in C.F.N.’s best interest.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of A.R.M., Children · filed 2015-11-04(2)

Having reviewed the evidence, we conclude it was legally and factually sufficient to support the trial court’s finding by clear and convincing evidence that termination of D.M.’s parental rights to A.R.M., N.A.M., and K.A.M. was in each child’s best interests.
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Section 161.001(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of S. R.- M. C. · filed 2015-11-17(2)

Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that termination of RAC’s parental rights was in SR-MC’s best interest.
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An affidavit of relinquishment can, by itself, support the best-interest finding required to terminate parental rights under Section 161.001.

in the Interest of A.P., a Child · filed 2015-11-19(b)(2)

An affidavit of relinquishment, in and of itself, is sufficient to support the best interest finding.
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Section 161.001 requires a finding that termination is in the child’s best interest in addition to a statutory ground for termination.

in the Interest of A.G. and F.G., Children · filed 2015-12-03(2)

Thus, we conclude that the evidence was both legally and factually sufficient to support the trial court’s finding that termination was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of E.R.W. and C.W., Children · filed 2015-12-03(b)(2)

The trial court could reasonably have formed a firm belief or conviction that it would be in the children’s best interest for Appellant’s parental rights to be terminated. We hold that the evidence is both legally and factually sufficient to support the trial court’s best interest finding.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of B.M.D.B., J.J.B., K.M.B., and V.D.C · filed 2015-12-09

We hold there was legally insufficient evidence supporting the trial court’s best-interest finding.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of J.M.H. · filed 2015-12-15(2)

We conclude that there was sufficient evidence for the trial court to form a firm belief or conviction that termination of parental rights was in the best interest of the child.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of N.S., a Child · filed 2015-12-15(2)

Applying the applicable Holley factors to the evidence, we conclude that legally and factually sufficient evidence supports the trial court’s finding that termination of the mother’s rights is in the best interest of N.S.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s repeated drug use and inability to provide a stable home can support that finding.

in the Interest of J.T., J.T., J.T., and J.T., Children · filed 2015-12-16(2)

After determination and weight of the Holley factors and viewing the evidence in the light most favorable to the finding, this court concludes the trial court could reasonably have formed a firm conviction that termination of Mother’s parental rights is in the children’s best interest. Thus, the evidence is legally sufficient to support this finding. Based upon the same evidence and conclusions, the evidence is also factually sufficient to support the trial court’s finding that termination was in the children’s best interest.
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Section 161.001(b)(2) requires proof that terminating parental rights is in the child’s best interest.

in the Interest of A.E.M., a Child · filed 2015-12-16(b)(2)

To terminate parental rights pursuant to section 161.001 of the Family Code, the Texas Department of Family and Protective Services has the burden to prove: (1) one of the predicate grounds in subsection 161.001(b); and (2) that termination is in the best interest of the child. ... Having reviewed the entire record, we hold the evidence is sufficient to support the trial court’s finding that termination was in A.E.M.’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of A.Y.W., a Child · filed 2015-12-17(b)(2)

To terminate 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)(A)–(T) and that termination is in the best interest of the child. ... We hold that the evidence is both legally and factually sufficient to support the trial court’s best interest finding.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

In the Interest of J.K.V. · filed 2016-01-22(b)(2)

Because the evidence is factually sufficient to support the trial court’s best-interest finding, we affirm the trial court’s judgment.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of A.K. · filed 2016-02-17(b)(2)

In other words, we hold the evidence is such that the trial court could have reasonably formed a firm belief or conviction that termination was in the child’s best interest.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest, in addition to proof of a statutory ground for termination.

in the Interest of D.R.L., C.L.W., Jr., and A.E.L., Children · filed 2016-02-18(b)(2)

In order to terminate the parent-child relationship, DFPS must establish, by clear and convincing evidence, one or more of the acts or omissions enumerated under Texas Family Code section 161.001(b)(1) and that termination is in the best interest of the child. ... Accordingly, we hold that the evidence is factually sufficient to support the trial court’s finding that termination of Luna’s parental rights was in the children’s best interest.
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Section 161.001(b)(2)’s best-interest requirement can be met by clear and convincing evidence of a parent’s ongoing failure to meet children’s needs, even when the children are bonded with the parent.

in the Interest of D.L.T., D.L., D.L., T.L., D.W. AKA D.T.W., D.W., Children v. Department of Family and Protective Serv · filed 2016-03-08(b)(2)

Given Mother’s unwillingness to provide a stable, clean, or suitable living environment for the children and her unwillingness to ensure that they are properly fed, clean, and educated, the trial court was presented with ample clear and convincing evidence that termination of Mother’s parental rights was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

In re T.R. · filed 2016-04-04(b)(2)

Having reviewed the evidence, we conclude it was legally and factually sufficient to support the trial court’s finding by clear and convincing evidence that termination of A.M.C.’s parental rights to T.R. was in T.R.’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of N.F.L. · filed 2016-04-13(b)(2)

Based on the foregoing, we hold the evidence is legally and factually sufficient to have permitted the trial court, in its discretion, to find termination was in N.F.L.’s best interest.
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Section 161.001(2) requires proof that termination is in the child’s best interest in addition to proof of a predicate ground.

in the Interest of K.A.D.K. and J.B.L.E., Children · filed 2016-04-20(2)

After determination and weight of the Holley factors and viewing the evidence in the light most favorable to the finding, this court concludes the trial court could reasonably have formed a firm conviction that termination of Mother’s parental rights is in the children’s best interest. Thus, the evidence is legally sufficient to support this finding. Based upon the same evidence and conclusions, the evidence is also factually sufficient to support the trial court’s finding that termination was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of J.K v. a Child · filed 2016-04-20(b)(2)

Based on this record, which established that (1) Vero’s parental rights were terminated the month after he was served with the Department’s suit, and (2) the Department made no effort to offer any services to Vero, we conclude that, when we weigh the Holley factors, the evidence is factually insufficient to support the determination that Justin’s best interest was served by terminating Vero’s parental rights.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of A.O.M and J.X.M., Children · filed 2016-04-26(b)(2)

Applying the applicable Holley factors to the evidence, we conclude that legally and factually sufficient evidence supports the trial court’s finding that termination of the parental rights of Audrey and Jerry is in the best interest of Alex and Joyce.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of D.E.B., S.B., J.B., Children · filed 2016-05-13(b)(2)

After viewing all of the evidence in the light most favorable to the best interest finding, we conclude the evidence was sufficiently clear and convincing that a reasonable fact finder could have formed a firm belief or conviction that termination of the parent-child relationship between the mother and S.B. and J.B. was in the children’s best interest.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of V.E., a Child · filed 2015-12-17(2)

Considering all the evidence in relation to the Holley factors in the light most favorable to the trial court’s best-interest finding, we hold that a reasonable factfinder could have formed a firm belief or conviction that termination of Appellant’s parental rights was in V.E.’s best interest.
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Section 161.001(b) requires clear and convincing evidence of a listed ground for termination and that termination is in the child’s best interest.

in the Interest of I.C., N.C., A.C., and D.C., Children · filed 2016-04-07(b)

For a trial court to terminate a parent-child relationship, TDFPS must establish by clear and convincing evidence that the parent’s actions satisfy one ground listed in family code section 161.001(b)(1) and that termination is in the best interest of the child.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest, even when the parents have a mediated settlement agreement.

in Re Barre Morris · filed 2016-06-22(2)

For these reasons, we conclude that section 153.0071(e) does not apply to suits for termination of the parent-child relationship under Chapter 161 of the Family Code and that a mediated settlement agreement therefore does not preclude a trial court from determining under section 161.001(2) whether the plaintiff has proved by clear and convincing evidence that termination would be in the child’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest, in addition to a predicate ground under subsection (b)(1).

in the Interest of K.M., I.D., and D.G., Children · filed 2016-06-29(b)(2)

The Family Code permits a trial court to terminate parental rights if the Department proves by clear and convincing evidence that the parent committed an action prohibited under section 161.001(b)(1) and termination is in the children’s best interest. ... Thus, we find that the evidence was legally and factually sufficient to support the best interest finding.
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Section 161.001 requires proof of a statutory ground for termination and that termination is in the child’s best interest.

in the Interest of A.D.L., Children · filed 2016-07-20(b)(2)

To terminate parental rights pursuant to section 161.001 of the Family Code, the Department has the burden to prove: (1) one of the predicate grounds in subsection 161.001(1)(b); and (2) that termination is in the best interest of the child. ... Having reviewed the record, we hold the evidence is sufficient to support the trial court’s finding that termination was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in Re R.M.M. · filed 2016-07-20(b)(2)

Having reviewed the evidence, we conclude it was legally and factually sufficient to support the trial court’s finding by clear and convincing evidence that termination of M.G.’s parental rights to R.M.M. was in R.M.M.’s best interest.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of Z.I.A.R., G.D.R., R.G.A.R., and R.L.F.R., Children · filed 2016-08-03(2)

Considering all the evidence in relation to the Holley factors in the light most favorable to the trial court’s best-interest finding, we hold that a reasonable factfinder could have formed a firm belief or conviction that termination of Appellant’s parental rights was in the children’s best interest.
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Section 161.001(b)(2) requires proof that terminating the parent-child relationship is in the child’s best interest.

in the Interest of E.N. and J.N., Children · filed 2016-08-22(b)(2)

The Texas Family Code permits a court to terminate the parent-child relationship if the petitioner establishes both (1) one or more acts or omissions enumerated under section 161.001(b)(1), and (2) that termination of the parent-child relationship is in the best interest of the child. ... From our review of the record, the evidence is factually sufficient to support the proposition that the trial court could reasonably form a firm belief or conviction that termination of N.D.’s parental rights was in the best interest of the children.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s drug use, unstable housing, and failure to engage in services can support that finding.

in the Interest of L.S., a Child · filed 2016-09-08(b)(2)

Viewing all the evidence in the light most favorable to the best-interest finding and considering the nonexclusive Holley factors, we hold that the trial court could have reasonably formed a firm conviction or belief that termination of the parent-child relationship between Mother and Leah was in Leah’s best interest, and we therefore hold the evidence legally sufficient to support the trial court’s best-interest finding.
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Section 161.001 requires proof that termination is in the child’s best interest.

in the Interest of T.M.C., A.M.C., and N.R.S.C. · filed 2016-09-14(b)(2)

To terminate parental rights pursuant to section 161.001 of the Family Code, the Department has the burden to prove: (1) one of the predicate grounds in subsection 161.001(b)(1); and (2) that termination is in the best interest of the child. ... Having reviewed the record, we hold the evidence is sufficient to support the trial court’s finding that termination was in the children’s best interest.
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Section 161.001(2) requires proof that termination is in the child’s best interest.

in the Interest of R.R. and S.M.R., Children · filed 2016-09-14(2)

Based on the foregoing, we hold the evidence is legally and factually sufficient to have permitted the trial court, in its discretion, to find termination was in the children’s best interest.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest; criminal conduct, instability, and failure to complete services can support that finding.

in the Interest of A. B., a Child · filed 2016-09-20(b)(2)

In a case to terminate parental rights under section 161.001 of the Family Code, the Department must establish, by clear and convincing evidence, that (1) the parent committed one or more of the enumerated acts or omissions justifying termination and (2) termination is in the best interest of the child. ... After considering the relevant factors under the appropriate standards of review, we hold the evidence is legally and factually sufficient to support the trial court’s finding that termination of the parent-child relationship is in A.B.’s best interest.
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Section 161.001 requires a statutory ground for termination and proof that termination is in the child’s best interest.

In the Interest of G.N. · filed 2016-09-21

We conclude that the evidence is factually sufficient to support the trial court’s determination that termination of Father’s parental rights is in the child’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of A.A v. Jr., a Child · filed 2016-09-28(b)(2)

Termination of parental rights under section 161.001 of the Texas Family Code requires proof by clear and convincing evidence that the parent committed one of the acts or omissions listed in section 161.001(1)(A)-(T) and that termination is in the child’s best interest. ... We conclude the evidence was legally and factually sufficient to support the trial court’s finding that termination of D.V.’s parental rights was in A.A.V. and B.M.V.’s best interest.
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Section 161.001 allows an irrevocable or unrevoked relinquishment affidavit to serve as a ground for termination, but the petitioner must also prove that termination is in the child’s best interest.

in the Interest of E.J.R., a Child · filed 2016-09-29(1)(K)

The same evidence of statutory acts or omissions under section 161.001(1) may be probative in determining the best interest of the child, but proof of these acts or omissions does not relieve the petitioner from showing the best interest of the child.
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Subsection (b)(2) requires clear and convincing evidence that termination is in the child’s best interest; unstable housing, drug use, and unmet needs can support that finding.

in the Interest of B.A.B., K.R.D., J.L.D. and I.L.D., Children · filed 2016-09-29(b)(2)

We hold that the evidence was legally sufficient to support the trial court’s finding that termination of the mother’s parental rights was in the children’s best interest. Considering the entire record, we likewise find the evidence factually sufficient to support the trial court’s best-interest finding.
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Section 161.001(b)(2) requires clear and convincing evidence that termination of parental rights is in the child’s best interest.

in the Interest of K v. a Child · filed 2016-10-11(b)(2)

Having considered the Holley factors and the need for prompt and permanent placement, we conclude there was clear and convincing evidence to support the trial court’s finding that termination of the parent- child relationship between J.V. and K.V. was in K.V.’s best interest.
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Section 161.001(b)(2) requires a finding that termination of parental rights is in the child’s best interest.

in the Interest of G.R., M.R., A.R., A.R., Children · filed 2016-10-25(b)(2)

When we look at all of the evidence in the light most favorable to the trial court’s ruling, we conclude that the evidence is such that a reasonable trier of fact could have formed a firm belief or conviction that termination of B.R.’s parental rights is in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s drug use, unstable home, and failure to complete services can support that finding.

in the Interest of L.A.M., Child · filed 2016-10-27(b)(2)

Applying the applicable Holley factors to the evidence, we conclude that legally and factually sufficient evidence supports the trial court’s finding that termination of Mother’s rights was in Lucy’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of U.D.R. and J.T.F., Children · filed 2016-11-16(b)(2)

We hold the evidence is legally and factually sufficient to have permitted the trial court, in its discretion, to find termination was in the best interest of U.D.R. and J.T.F.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of J.C.H. and J.D.H. · filed 2016-11-23(2)

On this record, we must conclude the evidence permitted a reasonable factfinder to form a firm conviction and belief that termination of the parent-child relationship was in the children’s best interest.
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Section 161.001(b) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of H.H.L., Jr., Children · filed 2016-11-23(b)

We hold a factfinder could reasonably form a firm belief or conviction that termination of Janie’s parental rights is in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of D.D. and D.D., Children · filed 2016-11-23(b)(2)

Having reviewed the evidence, we conclude it was legally and factually sufficient to support the trial court’s finding by clear and convincing evidence that termination of E.D.L.R.’s parental rights to DAN and DAR was in the children’s best interests.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of D. E. B., T.A.B. III AKA T.B, Jr., AKA T. J., Jr., T.B. AKA Baby Boy W., Children · filed 2016-12-22(b)(2)

Here, the Department was required to establish, by clear and convincing evidence, that Mother’s actions satisfied one of the predicate grounds listed in Family Code section 161.001(b)(1) and that termination was in the children’s best interest. See TEX. FAM. CODE ANN. 161.001(b)(1), (2). ... Therefore, after considering the relevant factors under the appropriate standards of review, we hold the evidence is legally and factually sufficient to support the trial court’s finding that termination of the parent-child relationship was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of A.M., A.M., & C.M., Children · filed 2016-12-27(b)(2)

Therefore, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that termination of J.M.’s parental rights is in the children’s best interest. See TEX. FAM. CODE ANN. § 161.001(b)(2).
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Section 161.001 requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of M.F.L. AKA M.F.O. and D.W.L. AKA D.W.O., Children · filed 2016-12-28(2)

We find that the evidence is legally and factually sufficient to support the trial court’s finding that termination is in the children’s best interest.
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Section 161.001(b)(2) permits termination when the evidence supports a firm belief or conviction that termination is in the child's best interest.

in the Interest of S v. and D v. Minor Children · filed 2016-12-30(b)(2)

Considering the evidence and comparing it to the standards of review and relevant legal factors considered in cases such as this, the jury could have reasonably formed a firm belief or conviction that termination of J.H.’s rights was in the best interests of S.V. and D.V.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; drug use, failure to complete services, prior endangerment findings, and a stable proposed placement can support that finding.

in the Interest of D.M.M., Child · filed 2017-01-05(b)(2)

Applying the applicable Holley factors to the evidence, we conclude that there was legally and factually sufficient evidence to reasonably establish a firm belief or conviction that termination of both parents’ parental rights is in the Child’s best interest.
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Section 161.001(b) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of S.L.M. · filed 2017-01-25(b)(2)

A judgment terminating parental rights must be supported by clear and convincing evidence. Tex. Fam. Code Ann. § 161.001(b) (West Supp. 2016). ... We hold a factfin-der could reasonably have formed a firm belief or conviction that termination of Yvonne’s parental rights to S.L.M. and L.P.M. is in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of F.M. III, Minor Child · filed 2017-01-30(b)(2)

Reviewing the evidence under the two sufficiency standards, and giving due consideration to evidence that the trial court could have reasonably found to be clear and convincing, we conclude the trial court could have formed a firm belief or conviction that terminating F.M. Jr.’s parental rights to F.M. III was in the child’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of B.G.M., Children · filed 2017-02-01(b)(2)

Having examined the evidence under the applicable standards of review, we conclude the evidence pertaining to the trial court’s findings is both legally and factually sufficient for the trial court to have found by clear and convincing evidence that terminating G.V.M.’s parental rights to the children was in the children’s best interests.
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The best-interest finding under section 161.001(b)(2) may be supported by evidence of a parent's abuse history, lack of a bond with the child, and inability to provide a safe home.

in the Interest of J.M.C., a Child · filed 2017-02-15(b)(2)

Having examined the evidence under the applicable standards of review, we conclude the evidence pertaining to the trial court’s findings is both legally and factually sufficient for the trial court to have found by clear and convincing evidence that terminating P.A.J.’s parental rights to J.M.C. was in J.M.C.’s best interest.
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Section 161.001(b)(2) does not require proof of every best-interest factor; missing evidence on some factors does not prevent a finding that termination is in a child's best interest.

in the Interest of M.J.B., S.D.B., D.M.B., and C.L.B., Children · filed 2017-02-15(b)(2)

There is no requirement that all of these factors must be proved as a condition precedent to parental termination, and the absence of evidence about some factors does not preclude a factfinder from reasonably forming a strong conviction that termination is in the children's best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of M.T. · filed 2017-02-22(b)(2)

Parental rights may be terminated only upon proof of clear and convincing evidence that (1) the parent has committed an act prohibited by section 161.001(b)(1) of the Texas Family Code, and (2) termination is in the best interest of the child. ... Thus, whether we look at all the evidence in the light most favorable to the trial court’s finding, or whether we look at all the evidence, including disputed or conflicting evidence, we conclude the trial court’s best interest finding is supported by sufficient evidence.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of J.I.M. · filed 2017-03-22(b)(2)

Parental rights may be terminated only upon proof of clear and convincing evidence that (1) the parent has committed an act prohibited by section 161.001(b)(1) of the Texas Family Code, and (2) termination is in the best interest of the child. ... Thus, whether we look at all the evidence in the light most favorable to the trial court’s finding, or whether we look at all the evidence, including disputed or conflicting evidence, we conclude the trial court’s best interest finding is supported by sufficient evidence.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of A.S., a Child · filed 2017-03-31(b)(2)

The trial court could reasonably have formed a firm belief or conviction that it would be in the child’s best interest for the mother’s and the father’s parental rights to be terminated. We hold that the evidence is both legally and factually sufficient to support the trial court’s best interest findings.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of L.A., a Child · filed 2017-04-06(b)(2)

The evidence presented was sufficient to support a finding that termination was in L.A.’s best interest.
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Section 161.001 requires a finding that termination is in the child’s best interest, even when a ground for termination is established.

in the Interest of J.M.B. and T.A.D.B., Children · filed 2017-04-27(b)(2)

For the court to terminate Mother’s parental rights, a jury would have to find Mother committed an act prohibited by section 161.001(b)(1) and that termination was in the best interest of the child.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of K.C., a Child · filed 2017-05-03(b)(2)

Considering all the evidence in relation to the Holley factors in the light most favorable to the trial court’s best-interest finding, we hold that a reasonable factfinder could have formed a firm belief or conviction that termination of B.W.’s parental rights was in the child’s best interest. Viewing all the evidence in relation to the Holley factors, we hold that a reasonable factfinder could have reasonably formed a firm belief or conviction that termination was in the child’s best interest. The evidence is therefore legally and factually sufficient to establish that termination was in the child’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of M. G., a Child · filed 2017-05-26(b)(2)

Therefore, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that termination of C.G.’s and G.G.’s parental rights is in the child’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; continued drug use and an inability to meet the children’s needs can support that finding.

in the Interest of T.A.P., Jr. Children · filed 2017-07-19(b)(2)

Viewing all of the evidence in the light most favorable to the trial court’s finding, we conclude the trial court could have formed a firm belief or conviction that terminating appellant’s parental rights was in the children’s best interest. Therefore, we conclude the evidence was legally sufficient to support the trial court’s best interest finding.
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Section 161.001(b) requires clear and convincing evidence to terminate parental rights, including a finding that termination is in the child’s best interest.

in the Interest of S.S., F.C.S. and A.C.S., Jr., Children · filed 2017-07-19(b)

A judgment terminating parental rights must be supported by clear and convincing evidence. TEX. FAM. CODE ANN. § 161.001(b) (West Supp. 2016). ... We hold a reasonable factfinder could have formed a firm belief or conviction that termination of Adelina’s parental rights is in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of N.A.C. Jr., J.A.C., and M.I.C. · filed 2017-07-19(b)(2)

Considering all the evidence in the light most favorable to the best interest finding, we conclude the trial court reasonably could have formed a firm belief or conviction that termination of appellant's parental rights was in the children’s best interest.
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Section 161.001 requires clear and convincing evidence that termination of parental rights is in the child’s best interest.

in the Interest of J.J.J., a Child · filed 2017-07-19(b)(2)

We hold a reasonable factfinder could have formed a firm belief or conviction that termination of Jane’s parental rights is in J.J.J.’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; evidence may be sufficient even when it does not address every Holley factor.

in the Interest of A.F.C., I.C.C., A.R.H., Jr., Children · filed 2017-07-26(b)(2)

Here, despite the lack of evidence as to all of the Holley factors, we hold the evidence that does exist is legally and factually sufficient to support the trial court’s finding that it was in the children’s best interests to terminate Mother’s parental rights.
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Section 161.001 requires a statutory ground for termination and a finding that termination is in the child’s best interest.

in the Matter of J.M.L., J.L.B., E.L., R.M.B., and M.E.L., Children · filed 2017-08-02(b)(2)

To terminate parental rights pursuant to section 161.001 of the Code, the Department has the burden to prove: (1) one of the predicate grounds in subsection 161.001(b)(1); and (2) that termination is in the best interest of the child. ... Having reviewed the record, we hold the evidence is sufficient to support the trial court’s finding that termination of S.B.’s parental rights was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of S.R.M., a Child · filed 2017-08-02(b)(2)

We hold the evidence is legally and factually sufficient to support the trial court’s best interest finding.
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Section 161.001(b) requires clear and convincing evidence that termination of parental rights is in the child’s best interest.

in the Interest of A.F v. a Child · filed 2017-08-02(b)

Having considered all of the evidence, we hold a factfinder could reasonably have formed a firm belief or conviction that termination of Joseph’s parental rights to A.F.V. is in A.F.V.’s best interest.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest, along with proof of a predicate act under subsection (b)(1).

in the Interest of J.C.M., a Child · filed 2017-08-02(b)(2)

Therefore, considering all the evidence in relation to the Holley factors in the light most favorable to the trial court’s best-interest finding, we hold that a reasonable factfinder could have formed a firm belief or conviction that termination of Amy and Doug’s parental rights was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of C.S. III, a Child · filed 2017-08-02(b)(2)

The Department was required to prove by clear and convincing evidence that termination of Appellant’s parental rights was in C.S.’s best interest. § 161.001(b)(2); In re K.M.L., 443 S.W.3d at 116. ... While we are not unsympathetic to Appellant’s well-intended desire to maintain a parent-child relationship with C.S., based on the totality of the evidence, we find that the Department presented clear and convincing evidence to support the trial court’s best interest finding.
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Section 161.001(b)(2) requires a best-interest finding supported by clear and convincing evidence; a parent’s recent improvement and compliance with services do not necessarily defeat that finding.

In the Interest of C.V. · filed 2017-08-25(b)(2)

Hence, the evidence supporting the court’s finding that termination of the mother’s parental rights was in the best interest of C.V. is legally and factually sufficient.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of L.P., I.B., P.S.S.-D., K.D., S.J., and S.J., Children · filed 2017-09-20(b)(2)

When we consider all of the Holley factors in light of the entire record, we conclude that a reasonable factfinder would have formed a firm belief or conviction that termination of A.M.’s parental rights to the children is in the children’s best interest.
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A parent's signed agreement that termination serves the children's best interest, considered with evidence of placement plans and statutory grounds for termination, can support a best-interest finding.

in the Interest of A.C., J.Y., J.Y. JR., L.B., and E.B., Children · filed 2017-05-02(b)(2)

We also observe that Mother’s agreements to termination under § 161.001(b)(1)(N) and (O) support inferences adverse to Mother regarding potential dangers to the children, her parenting abilities, and her relationships with the children. ... Based on J.R.W., we hold that the evidence was legally and factually sufficient to support the trial court’s best interest finding.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest, even when a predicate ground is established.

in the Interest of J.E.M.M & L.A.M.M, Children · filed 2017-10-25(b)(2)

Though we conclude the evidence is legally and factually sufficient to sustain the finding under the third predicate ground, we conclude the evidence is legally insufficient to support the best-interest finding.
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Section 161.001(b)(2)’s best-interest requirement can be satisfied by evidence of a parent’s instability, violent conduct, suicide attempts, and failure to complete required services.

in the Interest of J.A.T., a Child · filed 2017-11-01(b)(2)

Based on the foregoing, we hold the evidence is legally and factually sufficient to have permitted the trial court, in its discretion, to find that termination of Mother’s parental rights was in J.A.T.’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of T.A.C.G., T.M.G., III, N.L.G., T.M.G., and A.M.G., Children · filed 2017-11-15(b)(2)

The trial court could reasonably have formed a firm belief or conviction that it would be in each child’s best interest for Appellant’s parental rights to be terminated.
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Section 161.001 requires sufficient evidence that termination is in the child’s best interest; evidence beyond an affidavit of relinquishment may support that finding.

S. S. v. Texas Department of Family and Protective Services · filed 2017-12-08(b)(2)

For purposes of this appeal, however, the above issues are not dispositive, because in this case, there is legally and factually sufficient evidence to support the trial court’s best-interest finding beyond the affidavit of relinquishment alone.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of L. N. W . · filed 2017-12-14(b)(2)

In a case to terminate parental rights under section 161.001, the Department must establish, by clear and convincing evidence, that (1) the parent committed one or more of the enumerated acts or omissions justifying termination and (2) termination is in the best interest of the child.
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A best-interest finding under section 161.001(b)(2) is supported when the evidence permits a firm conviction that termination is in the child’s best interest.

in the Interest of M.S., Jr., a Child · filed 2018-01-04(b)(2)

Viewing all the evidence in the light most favorable to the best-interest finding and considering the nonexclusive Holley factors, we hold that the trial court could have reasonably formed a firm conviction or belief that termination of the parent-child relationship between Appellant and Mark was in Mark’s best interest, and we therefore hold the evidence legally sufficient to support the trial court’s best-interest finding.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of L.G. Children · filed 2018-01-10(b)(2)

Furthermore, assuming the Halsell harm analysis applies, in order to terminate Christy G.’s parental rights, the Department had the burden to prove by clear and convincing evidence: (1) one of the predicate grounds in subsection 161.001(b)(1); and (2) that termination is in the best interest of the children. ... The foregoing is legally sufficient evidence to support the trial court’s finding that termination of Christy G.’s parental rights was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of S.A., a Child · filed 2018-01-24(b)(2)

Based on the foregoing, we hold the evidence is legally and factually sufficient to have permitted the trial court, in its discretion, to find that termination of Mother’s parental rights was in the best interest of S.A.
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Section 161.001(b)(2) requires a finding that termination is in the child’s best interest, supported by clear and convincing evidence.

in the Interest of V.B. and T.B., Children · filed 2018-02-08(b)(2)

Based on our review of the entire record, the evidence was factually sufficient to support the trial court’s finding that it was in the children’s best interest.
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A parent may judicially admit subsection (b)(2)'s best-interest element, and a deemed admission can conclusively establish it in a termination suit brought by the other parent.

In the Interest of N.L.W. · filed 2017-10-06(b)(2)

While Section 161.001(b)(2) of the Texas Family Code requires a finding “that termination is in the best interest of the child,” the statute does not define that phrase. ... Consequently, whether termination of a parent-child relationship is in the child’s best interest is a matter capable of being judicially admitted under Rule 198. ... Accordingly, the deemed admissions constitute conclusive proof of the best interest element of K,A,’s claim as a matter of law.
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Section 161.001(b)(2) does not require a best-interest finding when parental rights are not terminated.

in the Interest of G v. III and G v. Children · filed 2017-12-18(b)(2)

Because Father’s and Mother’s parental rights were not terminated, there is no section 161.001(b)(2) finding to review, nor did the trial court need to make such a finding.
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Section 161.001(b)(2) requires clear and convincing evidence that termination of parental rights is in the child’s best interest.

in the Interest of K.L.M. and L.M.C., Children · filed 2018-02-21(b)(2)

Termination of parental rights requires the trial court to find, by clear and convincing evidence, that the parent has committed at least one statutory ground for termination and that termination is in the child’s best interest. ... Based on this record, we find that a rational jury could have reasonably formed a firm conviction that termination of Tammy’s parental rights was in K.L.M.’s and L.M.C.’s best interests.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of L.J.T., a Child · filed 2018-02-28(b)(2)

Based on a review of the entire record, we conclude the evidence is legally and factually sufficient to support the trial court’s finding, by clear and convincing evidence, that termination of Dad’s parental rights to L.J.T. is in L.J.T.’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; domestic violence, substance abuse, and an inability to provide a safe and stable home may support that finding.

in the Interest of S.M.R., S.L.R. and S.I.R. · filed 2018-03-14(b)(2)

We hold the evidence is legally and factually sufficient to support the trial court’s best interest finding that termination of Andrea G.’s parental rights is in the best interest of the children.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of R.G., Jr. · filed 2018-03-14(b)(2)

Thus, we hold the evidence is sufficient to support the trial court’s finding that termination of Mother’s parental rights was in her children’s best interests.
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Section 161.001(b)(2) requires clear and convincing evidence that termination of parental rights is in the child’s best interest.

in the Interest of C.S.L v. · filed 2018-03-14(b)(2)

A judgment terminating parental rights must be supported by clear and convincing evidence. TEX. FAM. CODE ANN. § 161.001(b) (West Supp. 2016). ... Having considered all of the evidence admitted at trial, we hold a reasonable factfinder could form a reasonably firm belief or conviction that termination of Brittany’s parental rights is in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of A.D.J., a Child · filed 2018-03-21(b)(2)

Viewing the evidence related to the Holley factors in the light most favorable to the trial court’s finding, we conclude the evidence is legally sufficient to support a firm belief or conviction that termination of Appellant’s parental rights was in A.D.J.’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of Z.C.I and I.V.I., Children · filed 2018-03-28(b)(2)

We hold that the evidence is both legally and factually sufficient to support the trial court’s best interest finding.
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Section 161.001(b) requires clear and convincing evidence of a statutory ground for termination and that termination is in the child’s best interest.

in the Interest of J.N.G. and C.Y.G. · filed 2018-03-28(b)

We hold the evidence is legally and factually sufficient to support the trial court’s best interest finding that termination of Michael G.’s parental rights is in the best interest of the children.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in Re A.J.M. and A.J.M. · filed 2018-03-28(b)(2)

Based on a review of the entire record, we conclude the evidence is legally and factually sufficient to support the trial court’s finding, by clear and convincing evidence, that termination of Dad’s parental rights to A.J.M. is in A.J.M.’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of D.D.P., C.L.C., E.L.C., and J.M.J. · filed 2018-04-04(b)(2)

Similarly, here, there is legally and factually sufficient evidence to support the trial court’s best interest finding.
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Section 161.001 requires proof that terminating parental rights is in the child’s best interest; evidence of the mother’s drug use, unstable home, and limited bond with the child supported that finding.

in the Interest of A.A.M., a Child · filed 2018-04-04(b)(2)

Thus, the evidence is both legally and factually sufficient to support the trial court’s best interest finding.
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Section 161.001(b)(2) requires proof that termination is in the child's best interest.

In re Interest of A.R.C. · filed 2018-04-06(b)(2)

In a single issue, Mother challenges the legal and factual sufficiency of the evidence supporting the trial court's finding that termination is in the best interest of the children under Section 161.001(b)(2) of the Family Code. ... Having reviewed all of the Holley factors, we conclude that the evidence is both legally and factually sufficient to establish a firm conviction or believe in the mind of the trial court that termination of Mother's parental rights is in the children's best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination of parental rights is in the child’s best interest.

in the Interest of C.M., G.M., J.W, and F.W., Children · filed 2018-05-09(b)(2)

After considering the Holley factors under our standard and scope of review, we conclude that the clear and convincing evidence before the fact-finder was legally and factually sufficient to support the conclusion that the termination of Sue’s parental rights was in the best interests of Gail, Calvin, James, and Faye.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of L.A.D-L., M.R.D-L., U.A.D-T, and D.R.D-T, Children · filed 2018-05-30(b)(2)

Having reviewed the record and considered all the evidence in the appropriate light for each standard of review, we conclude the trial court could have formed a firm belief or conviction that termination of Mother’s parental rights was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; persistent drug use, incomplete treatment, and unstable housing can support that finding.

in Re M.M.M. and L.M.M. · filed 2018-05-30(b)(2)

Thus, we hold the evidence is sufficient to support the trial court’s finding that termination of Father’s parental rights was in his daughters’ best interests and affirm the trial court’s termination order.
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Section 161.001(2) requires clear and convincing evidence that termination is in the child's best interest, in addition to proof of a statutory ground.

in the Interest of J.W. and C.W., Children · filed 2018-05-30(2)

Notwithstanding the sufficiency of the evidence to support termination under section 161.001(1), we must also find clear and convincing evidence that termination of the parent-child relationship was in the children's best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of L.L.C., Child v. Department of Family and Protective Services · filed 2018-06-07(b)(2)

In light of the entire record, we hold that factually sufficient evidence supports the court’s firm conviction and belief that termination of the mother’s parental rights was in the child’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest, but the Department need not prove every Holley factor.

T. L. v. Texas Department of Family and Protective Services · filed 2018-06-13(b)(2)

The Department need not prove all of the Holley factors as a “condition precedent” to termination, and the absence of some factors does not bar the factfinder from finding by clear and convincing evidence that termination was in a child’s best interest.
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Section 161.001(b)(2) requires a finding that termination is in the child’s best interest; continued drug use, unmet needs, and a stable adoptive placement can support that finding.

in the Interest of R.L.M. · filed 2018-06-13(b)(2)

In looking at all the evidence in the light most favorable to the trial court’s finding, we hold that the trial court could have reasonably formed a firm belief or conviction that termination of Laura C.’s parental rights was in R.L.M.’s best interest.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of H.D.M. and J.D.B. · filed 2018-06-14(b)(2)

Viewing the record as a whole, and having considered the Holley factors and the evidence the trial court had before it, we conclude the trial court’s best-interest finding is supported by legally and factually sufficient evidence.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of O.B. Jr. · filed 2018-03-28(b)(2)

Reviewing the evidence under the two standards, we conclude the trial court could have formed a firm belief or conviction that terminating M.G.’s parental rights to her children was in the children’s best interests.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s drug abuse and inability to provide a safe, stable home can support that finding.

in the Interest of A.M., a Child · filed 2018-06-22(b)(2)

Therefore, we find there is factually sufficient evidence to support the trial court’s best-interest finding, and we overrule this point of error.
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Section 161.001(b)(2) does not require proof of every Holley factor to establish that termination is in a child’s best interest.

J. A. and J. H. v. Texas Department of Family and Protective Services · filed 2018-07-18(b)(2)

Contrary to John’s assertion, the Department need not prove all of the Holley factors, and the absence of some factors does not bar the factfinder from finding by clear and convincing evidence that termination is in a child’s best interest, especially when there is undisputed evidence that the parental relationship endangered the child.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of R.H.Z., A.S.Z., and F.V.Z., Children · filed 2018-07-18(b)(2)

Having reviewed the evidence, we hold a factfinder could have reasonably formed a firm belief or conviction that termination of Raymond’s parental rights is in the children’s best interest.
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Section 161.001(b)(2)’s best-interest requirement can be supported by evidence of continued drug use, criminal activity, failure to complete services, and a stable prospective adoptive placement.

in the Interest of BBB, a Child · filed 2018-07-18(b)(2)

In looking at all the evidence in the light most favorable to the jury’s finding, we hold that the jury could have reasonably formed a firm belief or conviction that termination of Jadie B.’s parental rights was in B.B.B.’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of J.A.A., Jr., a Child · filed 2018-07-19(b)(2)

To terminate 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)(A)–(U) and that termination is in the best interest of the child. FAM. § 161.001(b). ... We hold that the evidence is both legally and factually sufficient to support the trial court’s best interest finding.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of R.M., C.S., I.S., and T.M., Children · filed 2018-07-19(b)(2)

Based on our thorough review of the record, we hold that the evidence was factually and legally sufficient to support the trial court’s finding that termination of Mother’s parental rights to C.S., I.S., and T.M. was in their best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of G.M., a Child · filed 2018-07-19(b)(2)

Reviewing all the evidence with appropriate deference to the factfinder, we hold that the trial court could have reasonably formed a firm conviction or belief that termination of the parent-child relationship between Mother and Garrett was in his best interest, and we therefore hold that the evidence is factually sufficient to support the trial court’s best-interest finding.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of J. B-F, a Child · filed 2018-07-25(b)(2)

Having reviewed all of the evidence, we hold a reasonable factfinder could have formed a firm belief or conviction that termination of Anna’s parental rights is in J.B.-F.’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of T.M.A. and Y.C.A, Children · filed 2018-08-01(b)(2)

To terminate parental rights pursuant to section 161.001 of the Texas Family Code, the Department has the burden to prove by clear and convincing evidence: (1) one of the predicate grounds in subsection 161.001(b)(1); and (2) that termination is in the best interest of the child. ... Having reviewed the record, we hold the evidence is legally and factually sufficient to support the trial court’s finding that termination of T.G.A.’s parental rights was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of K.R.S. · filed 2018-08-01(b)(2)

Having reviewed the record and considered all the evidence in the appropriate light for each standard of review, we conclude the trial court could have formed a firm belief or conviction that termination of Mother’s parental rights was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of J.P. and J.P., Children · filed 2018-08-09(b)(2)

For all of these reasons, considering all of the evidence under the factors described above, we conclude that the trial court could have formed a firm belief or conviction that termination of Mother’s parental rights is in the children’s best interest.
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Section 161.001(b)(2) requires evidence sufficient to support a firm belief that termination is in the child's best interest.

in the Interest of F.L., a Child · filed 2018-08-15(b)(2)

Using the Holley factors, and giving due deference to the trial court's fact findings, we find that the evidence was factually sufficient for the trial court to reasonably form a firm conviction or belief that termination of the parent-child relationship was in the best interest of the children.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of S.S.M. v. Department of Family and Protective Services · filed 2018-08-16(b)(2)

A trial court may order termination of the parent-child relationship if DFPS proves, by clear and convincing evidence, one of the statutorily enumerated predicate findings for termination and that termination of parental rights is in the best interest of the children.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; evidence addressing every Holley factor is not required.

in the Interest of N.M.H. and J.K.H., and J.J.W. · filed 2018-08-22(b)(2)

We therefore hold the evidence is sufficient to support the trial court’s finding that termination of Mother’s parental rights was in the best interests of her children.
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Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest; continued drug use and lack of stable housing can support that finding.

in the Interest of C.I.C. and V.A.L., Children · filed 2018-08-22(b)(2)

To terminate parental rights pursuant to section 161.001 of the Family Code, the Department has the burden to prove by clear and convincing evidence: (1) one of the predicate grounds in subsection 161.001(b)(1); and (2) that termination is in the best interest of the child. ... Having reviewed the record, we hold the evidence is sufficient to support the trial court’s finding that termination of Mother’s parental rights was in the children’s best interest.
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s continued drug use and the child’s need for a safe, permanent home can support that finding.

in the Interest of T.C., a Child · filed 2018-08-23(b)(2)

Based on the record before us, we conclude there was clear and convincing evidence to support the trial court’s findings that termination of S.C.’s parental rights to all three of her children is in their best interests.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of M. F., a Child · filed 2018-08-23(b)(2)

And we have concluded the evidence was sufficient to support the trial court’s findings under section 161.001(b)(2).
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Evidence that a parent cannot meet a medically fragile child’s care needs can support a best-interest finding under Section 161.001(b)(2).

K. N. M., A/K/A K. H. v. Texas Department of Family and Protective Services · filed 2018-08-28(b)(2)

Thus, the evidence in this record is factually sufficient to support the court’s best-interest finding under section 161.001(b)(2) of the Family Code.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in the Interest of P.L.G. and H.M.G., Children · filed 2018-08-28(b)(2)

From a review of these Holley factors, we conclude that the evidence is both legally and factually sufficient to establish a firm conviction in the mind of the trial court that termination of Tricia’s parental rights is in the best interest of Paul and Hailey.
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Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

T. W. v. Texas Department of Family and Protective Services · filed 2018-08-29(b)(2)

Thus, the evidence in this record is factually sufficient to support the court’s best-interest finding under section 161.001(b)(2) of the Family Code.
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Subsection (b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of R.V.P. and B.G.B. A/K/A B.P., Children · filed 2018-08-30(b)(2)

In view of the entire record, we conclude the disputed evidence is not so significant as to prevent the trial court from forming a firm belief or conviction that termination was warranted under section 161.001(b)(2).
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Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; continued drug use and inability to provide a safe, stable home can support that finding.

in the Interest of J. I. L. and A. v. L., Children v. Department of Family and Protective Services · filed 2018-09-27(b)(2)

Here, Mother’s history of past illegal drug abuse, continuing drug use while this case was pending, and her inability to demonstrate that she can provide a safe and stable home for her children supports the trial court’s best-interest determination.
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Notes 1501–1650 of 3,826, oldest cases first.

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