Tex. Fam. Code Ann. § 161.001

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of E.C.G., J.C.G., J.J.G., J.A.G., J.Z.G., and E.R.G. · filed 2020-11-25(b)(2)

We conclude the evidence is legally and factually sufficient to support the trial court’s finding that termination is in the children’s best interest, and we affirm the trial court’s order. ... To terminate parental rights under section 161.001 of the Texas Family Code, the Department must prove by clear and convincing evidence one of the grounds in subsection 161.001(b)(1) and that termination is in the best interest of the child.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of X.L. · filed 2020-12-10(b)(2)

We conclude that the Department established, by clear and convincing evidence, that termination of Father’s parental rights is in the best interest of X.L.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the children’s best interest; repeated failures to protect children from abuse can support that finding.

in the Interest of E.F., J.R.F., J.R.F., J.A.B., Children · filed 2020-12-17(b)(2)

Looking at the evidence of the Holley factors in the light most favorable to the trial court’s verdict, we conclude that the evidence is legally sufficient because a reasonable trier of fact could form a firm belief or conviction that termination was in the best interest of the children.

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 record permits a firm belief in that conclusion.

in the Interest of M.J. and M.J., Children · filed 2020-12-18(b)(2)

The trial court also found, pursuant to Section 161.001(b)(2), that termination of Appellant’s parental rights would be in the best interest of the children. ... We hold that the evidence is factually sufficient to support the trial court’s best interest finding as to each child.

Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

in Re J.O.H., A.F.B., H.R., J.J.R., and A.L.D., Children · filed 2020-12-18(b)(2)

In looking at all the evidence in the light most favorable to the trial court’s best-interest finding, we hold there is legally sufficient evidence to support the finding.

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.L.W., J.A.W. and A.M.M., Children v. Department of Family and Protective Services · filed 2020-12-22(b)(2)

Accordingly, we hold that the evidence is factually insufficient to support the trial court’s findings that termination of the parental rights of mother and father was in the best interest of A.M.M.

Section 161.001(b)(2) permits termination when clear and convincing evidence supports a finding that termination is in the children’s best interest.

in the Interest of L.M.H. Children v. . · filed 2021-01-13(b)(2)

Therefore, we hold the evidence is legally and factually sufficient to support the trial court’s best-interest finding. See TEX. FAM. CODE ANN. § 161.001(b)(2).

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of C.B. · filed 2021-01-15(b)(2)

In light of the entire record in this case, we conclude that the evidence, as outlined above, was legally and factually sufficient to support the trial court’s finding because, under either a legal sufficiency or a factual sufficiency review, the evidence would allow a reasonable factfinder to form a firm belief or conviction that termination of Mother’s parental rights was in C.B.’s and V.H.’s best interest.

Section 161.001(b) requires clear and convincing evidence of at least one listed ground for termination and that termination is in the child’s best interest.

in the Interest of C. J. a Child v. Department of Family and Protective Services · filed 2021-01-26(b)

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 in Texas Family Code section 161.001(b)(1) and that termination of parental rights is in the best interest of the child.

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.K.P., a Child v. . · filed 2021-02-03(b)(2)

Considering all the evidence under the two evidentiary standards, we conclude the trial court could have formed a firm belief or conviction that terminating Mom’s parental rights to her child was in the child’s best interest.

Section 161.001(b)(2) requires a finding that termination is in the child’s best interest; continued drug use, failure to comply with service plans, and a strong bond with foster parents can support that finding.

in the Interest of F.C. · filed 2021-02-04(b)(2)

Boiling it down, given a record containing evidence demonstrating Mother’s and Father’s past involvement with illegal drugs, showing they continued to use illegal drugs after John was removed from their home, indicating that the parents failed to fully comply with the requirements of their respective family service plans, and establishing that John has formed a strong bond with his foster parents and not with them, we hold the evidence is legally and factually sufficient to support the trial court’s finding that terminating their parental rights is in John’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of L.F., a Child · filed 2021-02-23(b)(2)

Looking to some of the Holley factors listed above and based on our review of the record as a whole, we conclude the evidence was capable of producing in the mind of the fact finder a firm belief or conviction that termination of the mother’s parental rights was in the best interests of her children.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of N.N.C. and G.L.N v. . · filed 2021-02-24(b)(2)

Therefore, we hold the evidence is legally and factually sufficient to support the trial court’s finding that termination of Trey’s parental rights was in N.N.C.’s best interest.

Section 161.001(b)(2)’s best-interest requirement can be supported without evidence on every best-interest factor if a reasonable factfinder could firmly believe termination serves the child’s best interest.

L. C. and S. B.-N. v. Texas Department of Family and Protective Services · filed 2021-03-26(b)(2)

We therefore cannot conclude that the evidence is legally insufficient to support the trial court’s finding that termination of L.C.’s rights is in the best interest of Kevin.

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.R.Q., a Child · filed 2021-03-31(b)(2)

Accordingly, we hold the evidence is legally and factually sufficient to support the trial court’s best-interest finding.

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 N.S.M., Child v. Department of Family and Protective Services · filed 2021-04-01(b)(2)

Thus, we hold that the evidence is factually sufficient to support the trial court’s best-interest finding.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of B.J.B. and J.D.D., Children · filed 2021-04-09(b)(2)

Having reviewed the record and considered 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 A.T.’s parental rights was in the children’s best interests.

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. M., H. M. and A. M., Children · filed 2021-04-21(b)(2)

After viewing the evidence in the light most favorable to the trial court’s best interest finding and applying the statutory and Holley factors, we conclude that a reasonable trier of fact could have formed a firm belief or conviction that termination of M.T.’s parental rights was in the best interest of the children.

Termination requires clear and convincing evidence that it is in the child’s best interest.

in the Interest of A.M.W. A/K/A A.W., K.R.W. A/K/A K.W., Children v. Texas Department of Family and Protective Services · filed 2021-04-22(b)(2)

After considering the entire record in light of the factors discussed above, we conclude that a factfinder could reasonably have formed a firm belief or conviction that termination was in the children’s best interests.

Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of C.C. and F.C., Children · filed 2021-04-22(b)(2)

Parental rights are appropriately terminated when the movant provides clear and convincing evidence that a parent has committed one predicate act prohibited by section 161.001(1) of the family code and termination is in the best interest of the child. ... Utilizing the appropriate standards and considering the appropriate evidence for father’s legal and factual sufficiency challenges, we conclude a reasonable fact finder could have formed a firm belief or conviction that termination was in the best interests of CC and FC.

Section 161.001(b)(2) requires a supported finding that termination is in the child’s best interest.

in the Interest of J.J., a Child · filed 2021-04-30(b)(2)

The foregoing evidence satisfies both aspects of the standard of review. It proves the evidence to be both legally and factually sufficient to support the finding that J.J.’s best interests were furthered through termination of the parental relationship.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of M.L.S., a Child · filed 2021-05-04(b)(2)

So we hold that the appellate record contains clear and convincing evidence upon which the trial court could legitimately determine that termination of the parental relationship was in the child’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the children’s best interest.

in the Interest of G.C., J.C., A.C., A.C., Children · filed 2021-05-13(b)(2)

Looking at the evidence of the Holley factors in the light most favorable to the trial court’s verdict, we conclude that the evidence is legally sufficient because a reasonable trier of fact could form a firm belief or conviction that termination was in the best interest of the children.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of K.K. · filed 2021-05-27(b)(2)

We conclude that the Department established, by clear and convincing evidence, that termination of B.V.’s parental rights is in the best interest of K.K.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a finding supported by legally and factually sufficient evidence may be upheld on appeal.

in the Interest of P.M., a Child · filed 2021-06-17(b)(2)

We hold that the trial court could reasonably have formed a firm belief or conviction that termination of Appellant’s parental rights would be in P.M.’s best interest.

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 H.S., a Child · filed 2021-06-23(b)(2)

Considering all the evidence under the two evidentiary standards, we conclude the trial court could have formed a firm belief or conviction that terminating Dad’s parental rights to H.S. was in H.S.’s best interest. See TEX. FAM. CODE ANN. § 161.001(b)(2); In re E.N.C., 384 S.W.3d 796, 807 (Tex. 2012).

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of J.H., J.H., and J.H., Children · filed 2021-06-30(b)(2)

And, ultimately, the clear and convincing evidence weighs in favor of the trial court’s finding that termination of April’s parental rights was in the best interest of the three children.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

Aguilar v. Solis · filed 2021-07-02(b)(2)

Based on our review of the entire record and applying proper deference to the trial court’s findings and credibility determinations, we cannot say that the trial court’s failure to form a firm conviction or belief that termination of Soliz’s parental rights was in C.A.’s best interest is so contrary to the overwhelming weight of the evidence as to be clearly wrong.

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. and C.M., Children · filed 2021-07-08(b)(2)

We hold the trial court’s best interest finding is supported by legally and factually sufficient evidence.

Section 161.001(b)(2)’s best-interest requirement can be satisfied by evidence of a parent’s past failure to protect the child, the risk of future harm, and the child’s progress in foster care, despite the parent’s employment, housing, and progress on a service plan.

in the Interest of J.G., a Child · filed 2021-07-15(b)(2)

In his sole issue, Father contends that the evidence is legally and factually insufficient to support the best-interest finding against him. Because we hold that the evidence is legally and factually sufficient to support that finding, we affirm the trial court’s judgment terminating Father’s parental rights to Joshua.

Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child's best interest, and evidence supporting a ground for termination may also support that finding.

in the Interest of W.T., a Child · filed 2021-07-20(b)(2)

Based on the evidence presented, we conclude it was sufficient to meet the clear and convincing burden of proof required to support the trial court’s finding that termination of W.T.’s parental rights was in his daughter’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; an appellate court must consider disputed evidence contrary to that finding.

S. G. and S. T. v. Texas Department of Family and Protective Services · filed 2021-08-06(b)(2)

In light of the entire record, we conclude that the disputed evidence regarding the best interest of the children is so significant that the factfinder could not have formed a firm belief or conviction that termination of Mother’s and Father’s parental rights was in the best interest of the children. Accordingly, the evidence is factually insufficient to support termination of their parental rights.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; evidence of substance abuse, unstable housing, lack of income, and limited visits can support that finding.

in the Interest of B.K.C., a Child · filed 2021-08-25(b)(2)

Therefore, the evidence was legally and factually sufficient to support the trial court’s best-interest-of-the-child finding with respect to Mom.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of G.Z., A.Z., H.Z., A.Z., A.Z., and J.D. · filed 2021-08-26(b)(2)

We conclude that, viewing the evidence in the light most favorable to the trial court’s best-interest findings, a reasonable factfinder could have formed a firm belief or conviction that termination of Mother’s and Father’s parental rights was in the three youngest children’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the children’s best interest; the finding can be upheld when the evidence is legally and factually sufficient.

in the Interest of S.T.F. and T.T.F., Children · filed 2021-09-01(b)(2)

We find that the evidence is legally and factually sufficient to support the trial court’s finding that ... termination of Lakisha’s parental rights is in the best interest of the children.

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. J. P. v. Department of Family and Protective Services · filed 2021-09-21(b)(2)

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 the best interest of O.J.P.

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.M. and M.J.C., Children · filed 2021-09-22(b)(2)

We therefore conclude legally and factually sufficient evidence supports the trial court’s best interest finding.

A best-interest finding under section 161.001(b)(2) can be supported by evidence of a parent’s physical abuse and failure to understand the children’s emotional needs.

in the Interest of D.R.P., T.M.B. Jr., J.D.B., and M.A.R.B., Children · filed 2021-10-06(b)(2)

Additionally, A.P.’s other acts and omissions, such as her physical abuse of the children and her failure to understand the children’s fragile emotional state, provide ample support for the best interest finding.

Section 161.001(b)(2) requires factually sufficient, clear and convincing evidence that terminating parental rights is in the child’s best interest.

E. E. v. Texas Department of Family and Protective Services · filed 2021-10-29(b)(2)

In light of the entire record, we cannot conclude that the Department met its burden to present evidence that was factually sufficient to support a finding that termination of Mother’s parental rights was in the best interest of the children.

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.C., a Child · filed 2021-11-04(b)(2)

Considering the Holley factors and viewing all the evidence, we conclude that the trial court could have reasonably formed a firm belief or conviction that termination of Mother’s parental rights was in Brandon’s best interests. See TEX. FAM. CODE ANN. § 161.001(b)(2).

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 A.G., a Child · filed 2021-11-17(b)(2)

Having reviewed the record and considered all the evidence in the appropriate light of each standard of review, we conclude the trial court could have reasonably formed a firm belief or conviction that termination of Mother’s and Father’s parental rights was in A.G.’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of B.L. and D.L., Children · filed 2021-11-18(b)(2)

In light of the evidence presented at trial and applying the Holley factors, we hold that the trier of fact could reasonably have formed a firm belief or conviction that termination of the father’s parental rights would be in the best interest of B.L. and D.L. See Holley, 544 S.W.2d at 371–72.

Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest.

R. M. v. Texas Department of Family and Protective Services · filed 2021-11-18(b)(2)

Viewing all the evidence in the light most favorable to the judgment, we conclude that a factfinder could have formed a firm belief or conviction that termination of Mother’s parental rights is in A.H.’s best interest.

Section 161.001(b)(2) requires proof that terminating parental rights is in the child’s best interest; a parent’s drug use and ability to provide a safe, stable home bear on that finding.

A. W. v. Texas Department of Family and Protective Services · filed 2021-12-15(b)(2)

Viewing the evidence under the legal sufficiency standard of review, we conclude that the trial court could have formed a firm belief or conviction that terminating Mother’s parental rights was in the children’s best interest.

Section 161.001(b)(2) requires a finding that termination is in the child’s best interest; continued alcohol abuse and unstable housing and employment can support that finding.

in the Interest of C.F., and B.F., Children · filed 2021-12-28(b)(2)

We hold that legally and factually-sufficient evidence supports the trial court’s finding that termination of Mother’s parental rights is in the best interest of the children.

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., AKA J.J.B v. Texas Department of Family and Protective Services · filed 2022-01-06(b)(2)

This finding must be supported by clear and convincing evidence, which is greater than the simple preponderance standard that applies more commonly in civil cases. See Tex. Fam. Code § 161.001(b)(2). ... Viewing the evidence in the light most favorable to the judgment for our legal-sufficiency analysis, and viewing all of the evidence equally for our factual-sufficiency analysis, we conclude that a reasonable factfinder could have formed a firm belief or conviction that termination of the Mother’s parental rights was in the Child’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of B.H. A/K/A M.O., a Child · filed 2022-01-06(b)(2)

We thus hold that the evidence is factually sufficient to support the trial court’s best-interest finding.

Section 161.001(b)(2) does not require definitive plans for permanent placement or adoption to establish that termination is in a child’s best interests.

in the Interest of A.A.Z., A.A.Z., and A.A.L., Children · filed 2021-11-10(b)(2)

However, it is not necessary for the Department to establish “definitive plans for permanent placement and adoption” to show that termination is in the children’s best interests.

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 Child · filed 2022-01-26(b)(2)

Based on this record, we conclude the trial court did not err in finding that the Department presented clear and convincing evidence to support a finding that termination of C.M.’s parental rights to A.M. was in her best interest.

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.C., X.I.C., Z.S.C., E.A.C., L.C.C., and A.R.G. · filed 2022-02-02(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 that parental rights should be terminated pursuant to one of the predicate grounds in subsection 161.001(b)(1) and that termination of parental rights is in the best interest of the child. ... Having reviewed the record and considered all the evidence in the appropriate light of each standard of review, we conclude the trial court could have reasonably formed a firm belief that termination of Mother’s parental rights was in the best interest of all the children.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of Z.H. and Z.H., Children · filed 2022-02-04(b)(2)

Considering the Holley factors and viewing all the evidence, we conclude that the trial court could have reasonably formed a firm belief or conviction, by clear and convincing evidence, that termination of Father’s parental rights was in Zach’s and Zeke’s best interests. See TEX. FAM. CODE ANN. § 161.001(b)(2) (Supp.).

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of B.Y., a Child · filed 2022-02-09(b)(2)

... evidence is legally sufficient to support the trial court’s finding that termination of David’s parental rights is in the best interest of B.Y.

Section 161.001(b)(2) requires a best-interest finding supported by evidence sufficient to give a reasonable factfinder a firm belief or conviction that termination serves the child’s best interest.

in the Interest of L.L.B, J.A.B, J.A.B, A.J.B., and B.B.L., Children · filed 2022-02-16(b)(2)

We therefore hold legally and factually sufficient evidence supports the trial court’s best interest finding, and we overrule A.L.’s arguments to the contrary.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of J.W. and B.W., Children · filed 2022-02-17(b)(2)

Giving due deference to the trial court, we hold that, based on the evidence presented at trial and the Holley factors, the trial court could reasonably have formed a firm belief or conviction that termination of Appellant’s parental rights would be in J.W.’s and B.W.’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of A.C., a Child · filed 2022-03-16(b)(2)

The Due Process Clause of the United States Constitution and section 161.001 of the Texas Family Code require application of the heightened standard of clear and convincing evidence in cases involving involuntary termination of parental rights. ... From this evidence in light of the applicable standards of review, we conclude that legally and factually sufficient evidence supports the associate judge’s finding that terminating Father’s parental rights is in A.C.’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of X.L.C., a Child · filed 2022-03-16(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 is in the child’s best interest.

Section 161.001(b)(2) permits a best-interest finding based on evidence of parents’ drug use, failure to complete required services, and the child’s stable foster placement.

in the Interest of G.S., a Child · filed 2022-03-23(b)(2)

Viewing all the evidence relating to the statutory and Holley factors in the light most favorable to the trial court’s finding, we conclude that a reasonable factfinder could have formed a firm belief or conviction that termination of Appellants’ parental rights is in G.S.’s best interest, and therefore, the evidence of best interest is legally sufficient.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

L.B. v. Texas Department of Family and Protective Services · filed 2022-03-29(b)(2)

After finding a predicate ground for termination, the trial court must determine whether there is clear and convincing evidence that termination is in the child’s best interest. Id. § 161.001(b)(2). ... Viewing the evidence in the light most favorable to the judgment for legal sufficiency and weighing the evidence equally for factual sufficiency, we conclude that a reasonable factfinder could have formed a firm belief or conviction that termination of Mother’s parental rights was in Child’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; missed visits, incomplete services, drug use, and the need for stability can support that finding.

E. H. v. Texas Department of Family and Protective Services · filed 2022-04-05(b)(2)

As to the trial court’s best-interest finding, we conclude that the evidence is legally sufficient to support the trial court’s finding that termination of Mother’s rights to her children was in their best interest.

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.R.M., a Child · filed 2022-04-06(b)(2)

Therefore, the evidence was legally and factually sufficient to support the trial court’s best-interest-of-the-child finding.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of S.H., A.H., and C.K., Children · filed 2022-04-07(b)(2)

We defer to the trial court’s finding as to the children’s best interest, see C.H., 89 S.W.3d at 27, and we cannot hold in this case that the trial court’s finding as to best interest is not supported by clear and convincing evidence.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; the child’s need for stability and permanency can support that finding.

in the Interest of S.G., Jr., a Child · filed 2022-04-14(b)(2)

For a trial court to terminate a parent–child relationship, the Department must prove two elements by clear and convincing evidence: (1) that the parent’s actions satisfy one ground listed in Family Code Section 161.001(b)(1); and (2) that termination is in the child’s best interest. ... The evidence showed the best choice for Ryan’s stability and permanency was remaining placed with the Department while it sought the best permanent placement.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; ongoing drug use and a stable foster placement can support that finding.

in the Interest of K.A.A., a Child · filed 2022-04-20(b)(2)

We conclude the evidence is legally and factually sufficient to establish a firm conviction in the mind of the trial court that termination of Mother’s parental rights is in the best interest of K.A.A.

Section 161.001 requires clear and convincing evidence of grounds for termination and that termination is in the child’s best interest.

in the Interest of A.R.M., a Child · filed 2022-04-27(b)

The record establishes by clear and convincing evidence the grounds for termination and that termination is in the child’s best interest. See TEX. FAM. CODE ANN. § 161.001; In re J.O.A., 283 S.W.3d 336, 344–45 (Tex. 2009); In re A.V., 113 S.W.3d 355, 362 (Tex. 2003).

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; parental drug use, unstable housing, and failure to complete services can support that finding.

in the Interest of E.D.S., a Child · filed 2022-05-11(b)(2)

The Due Process Clause of the United States Constitution and section 161.001 of the Texas Family Code require application of the heightened standard of clear and convincing evidence in cases involving involuntary termination of parental rights. ... We conclude the evidence supporting the finding that termination of Father’s parental rights was in the best interest of E.D.S. was both legally and factually sufficient.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s instability and failure to address concerns about the child’s safety can support that finding.

in the Interest of M.B.L. · filed 2022-05-19(b)(2)

Having considered the evidence related to best interest and deferring to the trial court’s determinations on witness credibility, the trial court’s resolution of conflicts in the evidence, and the weight to be given the testimony, we conclude that the statutory and Holley factors weigh in favor of the trial court’s finding that termination is in Martina’s best interest. See Tex. Fam. Code Ann. §§ 161.001(b)(2), 263.307(a); In re J.F.C., 96 S.W.3d at 266; Holley, 544 S.W.2d at 371-72. We conclude that the evidence is both legally and factually sufficient to support the trial court’s finding that termination of Renae’s parental rights is in Martina’s best interest, and we overrule Appellant’s issue.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of R.B.W., R.R.T., and R.L.T., Children · filed 2022-05-19(b)(2)

Giving due deference to the trial court, we hold that, based on the evidence presented at trial and the Holley factors, the trial court could reasonably have formed a firm belief or conviction that termination of Appellant’s parental rights would be in the best interest of R.B.W., R.R.T., and R.L.T.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest, with the child’s special needs considered alongside other relevant circumstances.

C. C. v. Texas Department of Family and Protective Services · filed 2022-05-20(b)(2)

In her sole issue on appeal, C.C. raises two arguments: first, that the evidence is legally insufficient to support the best-interest finding with respect to termination; and second, that the evidence is factually insufficient to support that finding. We disagree with the first assertion but agree with the second.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest, even when a statutory ground for termination is established.

in the Interest of W.G., a Child · filed 2022-05-20(b)(2)

Notwithstanding the sufficiency of the evidence to support termination under section 161.001(b)(1), we must also find clear and convincing evidence that termination of the parent-child relationship was in the best interest of W.G.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of B.O.R., a Child v. Texas Department of Family and Protective Service · filed 2022-05-24(b)(2)

Viewing all of the evidence equally for our factual- sufficiency analysis, we conclude that a reasonable factfinder could have formed a firm belief or conviction that termination of the Mother’s parental rights was in the Child’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of P.Y.-R. A. and P.R.W., Children · filed 2022-05-25(b)(2)

We therefore hold legally and factually sufficient evidence supports the trial court’s best interest finding, and overrule J.W.’s arguments to the contrary.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of Z.O., a Child · filed 2022-05-26(b)(2)

Giving due deference to the jury and the trial court, we hold that, based on the evidence presented at trial and the Holley factors, the trier of fact here could reasonably have formed a firm belief or conviction that termination of Appellant’s parental rights would be in the best interest of Z.O.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of T.C. and K.C., Children · filed 2022-05-26(b)(2)

Having reviewed the record and considered 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 Father’s parental rights is in the children’s best interests. See TEX. FAM. CODE ANN. § 161.001(b)(2). Accordingly, we hold the evidence is legally and factually sufficient to support the trial court's best-interest findings.

A suitable future placement is relevant to the best-interest finding under Section 161.001(b)(2), but its absence does not determine the issue.

L. M. v. Texas Department of Family and Protective Services · filed 2022-05-27(b)(2)

However, the lack of a suitable future placement for Daughter is but one Holley factor, relevant but not determinative of best interest.

Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interests.

in the Interest of E.A.T. Jr. and E.A.T., Children · filed 2022-04-06(b)(2)

Evidence was legally and factually sufficient to support the trial court’s findings by clear and convincing evidence that termination of Dad’s parental rights is in their best interests.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; domestic violence, instability, and failure to engage in services can support that finding.

A. F. v. Texas Department of Family and Protective Services · filed 2022-06-09(b)(2)

Considering the entire record, we conclude that the disputed evidence is not so significant that the factfinder could not have formed a firm belief or conviction that termination is the best interest of the children.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; parental drug use, lack of a stable home, missed visits, and the children’s stability in a prospective adoptive home can support that finding.

J. S. v. Texas Department of Family and Protective Services · filed 2022-06-17(b)(2)

On this record, we cannot conclude that the evidence is insufficient to support the jury’s finding that termination of Father’s parental rights is in the boys’ best interest.

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.W. and J.W., Children · filed 2022-06-22(b)(2)

We conclude that the Department has carried its heavy burden to establish that terminating Mother’s parental rights was in the best interest of these two children.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of K.G. and K.G., Children · filed 2022-06-23(b)(2)

Upon considering the record as it relates to the desires of the children, the emotional and physical needs of the children now and in the future, the emotional and physical danger to the children now and in the future, the parental abilities of those involved, the plans for the children by the Department, Appellant’s drug use, the use of drugs by Appellant’s paramour (with whom he lived at the time of trial), Appellant’s failure to visit or have any contact with the children for over a year, and the instability of Appellant’s situation, we hold that the evidence is legally and factually sufficient to support the finding that termination of Appellant’s parental rights is in the best interest of K.G. and K.G. See id.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; unstable housing, drug use, and failure to complete services may support that finding.

in the Interest of M.K.E. AKA M.K.E., AKA M.E. AKA M.E. v. Department of Family and Protective Services · filed 2022-06-23(b)(2)

Multiple factors support the trial court’s finding that termination of Mother’s parental rights was in Matthew’s best interest, including her failure to maintain a safe and stable home during the pendency of the case, her prior drug use coupled with her failure to submit to drug testing, and her undisputed failure to comply with her family service plan.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; the court may consider the parent’s conduct and the child’s safety and stability.

in the Interest of V.S., a Child · filed 2022-06-23(b)(2)

We hold that the evidence is legally and factually sufficient to show that terminating Father’s parental rights was in the best interest of V.S., and we overrule Father’s sole issue.

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.F., a Child · filed 2022-06-24(b)(2)

The United States Constitution and section 161.001 of the Texas Family Code require that in cases involving potential involuntary termination of a parent’s rights to her child, the Department is required to prove its case by clear and convincing evidence. ... We conclude that legally and factually sufficient evidence supported the trial court’s best-interest finding.

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 X.T. and L.T. · filed 2022-06-29(b)(2)

In reviewing all the evidence in the light most favorable to the trial court’s finding, we conclude a reasonable factfinder could have formed a firm belief or conviction that termination of Appellant Mother’s parental rights was in her children’s best interest.

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 v. a Child · filed 2022-06-29(b)(2)

After reviewing the evidence under the appropriate standards of review, we conclude a reasonable factfinder could have formed a firm belief or conviction that termination of Mother’s parental rights was in M.V.’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; continued drug use and danger to the child may support that finding.

in the Interest of M.A., a Child · filed 2022-06-30(b)(2)

Upon considering the record as it relates to the desires of the child, the emotional and physical needs of the child now and in the future, the emotional and physical danger to the child now and in the future, the parental abilities of those involved, the plans for the child by the Department, Appellant’s continued use of methamphetamine while the case was pending below, and Appellant’s continued relationship with the father—who also abused methamphetamine, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that termination of Appellant’s parental rights is in the best interest of M.A.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of A v. a Child · filed 2022-06-30(b)(2)

The trial court also found, pursuant to Section 161.001(b)(2), that termination of the mother’s and the father’s parental rights would be in the best interest of their child. ... Giving due deference to the trial court, we hold that, based on the 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 and the father’s parental rights would be in the best interest of A.V.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; recurring drug use, domestic violence, and the children’s need for stability can support that finding.

S. S. v. Texas Department of Family and Protective Services · filed 2022-07-08(b)(2)

Viewing all the evidence in the light most favorable to the trial court’s decree, we conclude that a fact finder could have formed a firm belief or conviction that termination of Mother’s parental rights is in the best interest of her four children.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of X.H. and A.B.M., Children · filed 2022-07-20(b)(2)

Therefore, the evidence was legally and factually sufficient to support the trial court’s best-interests-of-the-children finding.

Section 161.001(b)(2) requires clear and convincing evidence that terminating the parent–child relationship is in the child’s best interest.

in the Interest of M. H., a Child · filed 2022-07-21(b)(2)

We hold that under the applicable review standards, a factfinder could reasonably form a firm belief or conviction that terminating Mother’s parental rights was in Maxie’s best interest and that the evidence is therefore legally and factually sufficient to support the best-interest finding. See H.R.M., 209 S.W.3d at 108; J.P.B., 180 S.W.3d at 573; see also Tex. Fam. Code Ann. § 161.001(b)(2).

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 Z.R.F.M., Z.T.P., Z.R.N.R., and Z.J.A.P., Children · filed 2022-08-03(b)(2)

Therefore, the evidence was legally and factually sufficient to support the trial court’s best-interests-of-the-children finding.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in each child’s best interest.

in the Interest of M.H. and H.H., Children · filed 2022-08-05(b)(2)

On this record, the trial court could have formed a firm belief or conviction that termination was in the best interest of each child.

Section 161.001(b)(2)’s best-interest requirement can be supported by evidence of family violence, lack of contact with the children, failure to complete services, continued criminal conduct, and a stable foster placement.

in the Interest of E.L.H., M.L.H., J.O., and I.L.H., Children · filed 2022-08-25(b)(2)

Nevertheless, having considered the entire record under the appropriate standards, we conclude that the trial court could have formed a firm belief or conviction that terminating Father’s parental rights was in the children’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest; the court upheld that finding after reviewing the disputed evidence.

S.L. v. Department of Family and Protective Services · filed 2022-09-08(b)(2)

Considering and weighing the disputed evidence contrary to the best-interest determination against all the evidence favoring the best-interest determination, giving due deference to the trial court’s findings, and after an exacting review of the entire record with a healthy regard for the constitutional interests at stake, we conclude the evidence is such that a factfinder could reasonably form a firm belief or conviction that termination of Mother’s parental rights was in Andie’s best interest. See In re A.B., 437 S.W.3d at 503; In re J.O.A., 283 S.W.3d at 345. Thus, the evidence is not factually insufficient regarding the trial court’s best-interest determination.

Termination requires clear and convincing evidence that ending the parent-child relationship is in the child’s best interest.

M. P. A/K/A M. D., J. J. L.-B., and C. J. L. v. Texas Department of Family and Protective Services · filed 2022-09-16(b)(2)

Applying the applicable standards of review, we conclude that the evidence was not legally or factually sufficient to support a conclusive finding that it was in Child’s best interest to terminate Father’s parental rights.

Section 161.001(b)(2) does not require a witness to expressly state that termination is in the child’s best interest.

in the Interest of L.M. and S.M., Children · filed 2022-09-16(b)(2)

Nor does the statute require that someone, either expert or lay, so expressly opine. Rather, the trial court may terminate upon finding, by clear and convincing evidence, the existence of a statutory predicate and “that termination is in the best interest of the child.” TEX. FAM. CODE ANN. § 161.001(b)(1), (2).

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; continuing drug use, domestic violence, and an inability to provide a safe home can support that finding.

in the Interest of A.K. and J.K., Children · filed 2022-09-29(b)(2)

We hold that the evidence is legally and factually sufficient to show that terminating Father’s and Mother’s parental rights was in the best interest of Ann and Bruce.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of R.L.R., a Child · filed 2022-10-06(b)(2)

Giving due deference to the trial court, we hold that, based on the evidence presented at trial and the Holley factors, the trial court could reasonably have formed a firm belief or conviction that termination of Appellant’s parental rights would be in the best interest of R.L.R.

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.W., a Child · filed 2022-10-13(b)(2)

In summation, the evidence presented at trial was both legally and factually sufficient to support a finding that termination was in the child’s best interest by applying the Holley and statutory factors.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of T.G. and C.M., Children · filed 2022-10-20(b)(2)

Giving due deference to the trial court, we hold that, based on the evidence presented at trial and the Holley factors, the trial court could reasonably have formed a firm belief or conviction that termination of Appellant’s parental rights would be in the best interest of T.G. and C.M.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of I.B., I.B., and J.B., Children · filed 2022-10-27(b)(2)

Based on our review of the Holley factors as applied to the evidence here, we hold that the evidence is legally and factually sufficient to show that terminating Mother’s parental rights was in the best interest of Abby, Brian, and Charles.

Evidence supporting a ground for termination under subsection (b)(1) may also support a best-interest finding under subsection (b)(2).

in the Interest of C.B., C.B., and K.B., Children · filed 2022-10-27(b)(2)

Evidence probative of a child’s best interest may be the same evidence that is probative of a Subsection (b)(1) ground. Id. at 249; In re C.H., 89 S.W.3d 17, 28 (Tex. 2002); see Tex. Fam. Code Ann. § 161.001(b)(1), (2).

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

S. E. and K. D. v. Texas Department of Family and Protective Services · filed 2022-10-28(b)(2)

After reviewing the record, we conclude the evidence would allow a reasonable factfinder to come to a firm belief or conviction that termination of Mother’s parental rights is in Jimmy’s best interest. The evidence is therefore both legally and factually sufficient to support the best-interest finding, and we reject Mother’s sufficiency challenge to that finding.

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 G.K.T., a Child · filed 2022-11-02(b)(2)

We conclude the evidence is legally sufficient to support the trial court’s finding that termination of Father’s parental rights was in the child’s best interest.

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.G.D. and R.O.B, Children · filed 2022-11-23(b)(2)

Accordingly, after viewing all of the evidence in the light most favorable to the best-interest finding, we conclude that the trial court could have formed a firm belief or conviction that termination of N.D.’s and J.B.’s parental rights was in L.G.D.’s and R.O.B.’s best interest.

Section 161.001(b)(2) requires a finding that termination is in the child’s best interest, assessed under the Holley factors in light of the totality of the circumstances.

Y. A. v. Texas Department of Family and Protective Services · filed 2022-11-29(b)(2)

“We must consider ‘the totality of the circumstances in light of the Holley factors’ to determine whether sufficient evidence supports” the best-interest finding.

Section 161.001(b)(2)’s best-interest requirement can be satisfied by evidence of a parent’s continuing criminal conduct and inability to provide a safe, stable home.

G. C. v. Texas Department of Family and Protective Services · filed 2022-11-30(b)(2)

Viewing all the evidence in the light most favorable to the trial court’s decree, we conclude that a reasonable factfinder could have formed a firm belief or conviction that termination of Father’s parental rights is in Glen’s best interest.

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.E.J.A., a Child · filed 2022-12-07(b)(2)

Therefore, we hold the evidence is legally and factually sufficient to support the trial court’s best interest finding, and we overrule A.A.’s sole issue.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a court may uphold that finding when the evidence supports a firm belief or conviction that termination serves the child’s best interest.

in the Interest of N v. a Child · filed 2022-12-15(b)(2)

Giving due deference to the trial court, we hold that, based on the evidence presented at trial and the Holley factors, the trial court could reasonably have formed a firm belief or conviction that termination of Appellant’s parental rights would be in the best interest of N.V. See Holley, 544 S.W.2d at 371–72.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of M.R. and X.R., Children · filed 2022-12-22(b)(2)

Having reviewed the entire record, including the trial court’s findings of fact and conclusions of law, we conclude that a reasonable factfinder could not have formed a firm belief or conviction that termination was in the children’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

in the Interest of A.G., J.A., and K.A., Children · filed 2023-01-26(b)(2)

Instead, a reasonable trier of fact could have formed a firm belief or conviction that termination of Mother’s parental rights was in the children’s best interests, and the contrary evidence was not so significant as to preclude such a finding.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s drug use and unstable housing may support that finding.

in the Interest of J.J.W., Child(ren) · filed 2023-01-27(b)(2)

Viewing the evidence, both in the light most favorable to the trial court’s finding and as a whole, we conclude that a reasonable factfinder could have formed a firm belief or conviction that termination of Father’s parental rights was in J.J.W.’s best interest. Accordingly, we conclude that the evidence is both legally and factually sufficient to support the trial court’s best interest finding. See FAM. § 161.001(b)(2).

A best-interest finding can be supported by evidence of parental endangerment and recurring drug use even if the evidence does not address every Holley factor.

in the Interest of B.A.B. and T.G.K. · filed 2023-02-02(b)(2)

Because the evidence is legally and factually sufficient to support the trial court’s best-interest findings, we overrule Brenda’s sole issue.

Section 161.001(b)(2) requires a best-interest finding that may stand even if the Department fails to locate other relatives or fictive kin for placement.

In the Interest of A.T., a Child v. the State of Texas · filed 2023-02-23(b)(2)

Moreover, any failure of the Department to locate other relatives or fictive kin for the potential placement of A.T. does not alter our conclusion that the evidence is legally and factually sufficient to support the finding of the trier of fact that the termination of Appellant’s parental rights would be in A.T.’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; continued drug use, housing instability, missed visits, and a stable foster placement may support that finding.

In the Interest of A.Y.A., R.D.A., and J.A.A., Children v. the State of Texas · filed 2023-02-23(b)(2)

We conclude that the evidence was legally and factually sufficient to support the trial court’s finding that termination of the parent-child relationship was in the best interest of each child.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s drug use, violence, and failure to complete services can support that finding.

In the Interest of A.N.C., E.L.G., I.C.C.-G., and O.N.C.-G., Children v. the State of Texas · filed 2023-03-01(b)(2)

We therefore hold that legally and factually sufficient evidence supports the trial court’s best interest finding, and we overrule S.G.’s arguments to the contrary.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s ongoing drug use and the child’s stable foster placement can support that finding.

In the Interest of J.P.S., a Child v. the State of Texas · filed 2023-03-02(b)(2)

Having considered the entire record under the appropriate standards of review, we conclude that the trial court could have formed a firm belief or conviction that terminating Mother’s parental rights was in the child’s best interest. See TEX. FAM. CODE ANN. § 161.001(b)(2). Consequently, the evidence was legally and factually sufficient to support the trial court’s best-interest finding, and Mother’s sole issue is overruled.

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 K.A., M.A., and P.G., Children v. the State of Texas · filed 2023-03-09(b)(2)

Based on all the evidence and applying the appropriate standards of review, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that termination of Mother’s parental rights to Kyle, Mindy, and Peter was in the children’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of Z.R.M., a Child v. the State of Texas · filed 2023-03-15(b)(2)

After reviewing the evidence under the appropriate standards of review, we conclude a reasonable factfinder could have formed a firm belief or conviction that termination of F.E.C.’s parental rights was in Z.R.M.’s best interest. In re J.F.C., 96 S.W.3d at 266. We therefore hold legally and factually sufficient evidence supports the trial court’s best interest finding, and we overrule F.E.C.’s arguments to the contrary.

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 I.H., a Child v. the State of Texas · filed 2023-03-23(b)(2)

Giving due deference to the trial court, we hold that, based on the evidence presented at trial and the Holley factors, the trial court could reasonably have formed a firm belief or conviction that termination of Appellant’s parental rights would be in the best interest of I.H. See Holley, 544 S.W.2d at 371–72.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; neglect of medical and educational needs, an unstable home, and dangerous conduct can support that finding.

In the Interest of L.S.S., A/K/A L.S.G., a Child v. Texas Department of Family and Protective Services · filed 2023-03-30(b)(2)

Considering the entire record, we conclude that the evidence is legally and factually sufficient to support the trial court’s finding that termination of Mother’s parental rights was in L.S.’s best interest.

Section 161.001(b)(2)’s best-interest requirement can be satisfied by evidence of a parent’s drug use during pregnancy, continued drug use, and inability to provide a stable home.

In the Interest of P.L., a Child v. the State of Texas · filed 2023-03-30(b)(2)

Applying the appropriate standards of review, we conclude that legally and factually sufficient evidence supports the trial court’s best-interest finding.

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.O., a Child v. the State of Texas · filed 2023-04-06(b)(2)

Based upon our review of the record, we hold that the evidence is factually insufficient to support the trial court’s finding that termination of Appellant’s parental rights is in the best interest of A.O.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of N.B., A.B., V.Z., A.Z., A.Z., and A.Z., Children v. the State of Texas · filed 2023-04-13(b)(2)

Giving due deference to the trial court, we hold that, based on the evidence presented at trial and the Holley factors, the trial court could reasonably have formed a firm belief or conviction that termination of Appellant’s parental rights would be in the best interest of N.B. and A.B.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of T. S. S. C., M. M. H. and M. K. W., Children v. the State of Texas · filed 2023-04-20(b)(2)

Reviewing the evidence under the appropriate standards, including the statutory and Holley factors, we conclude that a reasonable trier of fact could have formed a firm belief or conviction that termination of K.G.’s parental rights was in the children’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of L.C.C. Jr., a Child v. the State of Texas · filed 2023-04-27(b)(2)

Upon considering the record as it relates to the actions of the mother and the father, the emotional and physical danger to the child now and in the future, the apparent desires of the child, the emotional and physical needs of the child now and in the future, the parental abilities of those involved, the domestic violence in the parents’ home, and the plans for the child by the Department, we hold that the evidence is legally and factually sufficient to support (1) the finding that termination of the mother’s parental rights is in the best interest of the child and (2) the finding that termination of the father’s parental rights is in the best interest of the child.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of J.W., a Child v. the State of Texas · filed 2023-05-03(b)(2)

Giving due regard to that presumption of keeping a child with the parent, the evidence presented at trial, and the Holley factors, we hold, as explained below, that the evidence is legally and factually sufficient to support the trial court’s finding that termination of Appellant’s parental rights would be in the best interest of J.W.

Section 161.001(b)(2) requires factually sufficient, clear and convincing evidence that termination is in the child’s best interest.

In the Interest of J.B. and J.S., Children v. the State of Texas · filed 2023-05-03(b)(2)

Because we have held that the evidence in this case is factually insufficient to support the finding made by the trial court pursuant to Section 161.001(b)(2), we need not address the factual sufficiency of the evidence with respect to the trial court’s findings under Section 161.001(b)(1).

Section 161.001 requires proof that a parent committed a listed act and that termination is in the child’s best interest.

In the Interest of M.A.C., Jr., a Child v. the State of Texas · filed 2023-05-05(b)(2)

To terminate parental rights, the evidence must show that the parent committed one of the acts enumerated in section 161.001(b)(1)(A)–(U) and that termination is in the best interest of the child. ... Based on our review of the record, we conclude that the evidence is legally and factually sufficient to support a firm belief or conviction that terminating the parent-child relationship between Mother and M.A.C. was in the best interest of the child.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of C.D., a Child v. the State of Texas · filed 2023-05-11(b)(2)

Giving due deference to the trial court, we hold that, based on the evidence presented at trial and the Holley factors, the trial court could reasonably have formed a firm belief or conviction that termination of Appellant’s parental rights would be in the best interest of C.D.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the children’s best interest; persistent family violence and the children’s expressed wishes supported that finding here.

In the Interest of D.W., K.W. and L.W., Children v. the State of Texas · filed 2023-05-11(b)(2)

Having reviewed all the evidence according to the proper standards of review, see Z.N., 602 S.W.3d at 545 (providing legal-sufficiency standard of review); C.H., 89 S.W.3d at 18–19, 28 (providing factual-sufficiency standard of review), we hold that the evidence is legally and factually sufficient to support the trial court’s best-interest finding against Father.

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 E.P.A. and E.C.A., Children v. the State of Texas · filed 2023-05-17(b)(2)

Therefore, the evidence was legally and factually sufficient to support the trial court’s best-interests-of-the-children findings.

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 Z.G., a Child v. the State of Texas · filed 2023-05-18(b)(2)

Based on our exacting review of the entire record and giving due deference to the factfinder’s findings, we likewise conclude that the evidence is factually sufficient to support the trial court’s best-interest finding.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; evidence that a foster family meets the child’s needs and hopes to adopt is insufficient by itself.

S. L. and J. R. v. Texas Department of Family and Protective Services · filed 2023-05-18(b)(2)

However, the Department did not provide factually sufficient evidence to show that termination is in Ella’s best interest.

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 H.C., a Child v. the State of Texas · filed 2023-05-24(b)(2)

“In order to terminate parental rights, the trial court must find, by clear and convincing evidence, that the parent has engaged in at least one statutory ground for termination and that termination is in the child’s best interest.” Id. (citing TEX. FAM. CODE ANN. § 161.001; In re E.N.C., 384 S.W.3d 796, 798 (Tex. 2012)). ... After weighing all the evidence and considering the Holley factors, we conclude that factually sufficient evidence supported the trial court’s best-interests finding.

Section 161.001(b)(2)’s best-interest requirement may be satisfied by evidence of a parent’s longstanding drug use and the child’s need for a safe, permanent home.

In the Interest of K.R.K.-L.H. v. the State of Texas · filed 2023-05-25(b)(2)

Because the evidence is legally and factually sufficient to support the trial court’s best-interest finding, we overrule Mother’s second issue.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of L.R., a Child v. the State of Texas · filed 2023-05-25(b)(2)

Giving due deference to the trial court, we hold that, based on the 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 and the father’s parental rights would be in the best interest of L.R.

Section 161.001(b)(2) requires a finding that termination is in the child’s best interest, supported by legally and factually sufficient evidence.

In the Interest of M.J., a Child v. the State of Texas · filed 2023-05-25(b)(2)

Because we determine that the evidence was both legally and factually sufficient to support the jury’s best-interest finding––and therefore that any deficient performance did not prejudice the case’s outcome––we affirm.

Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest; evidence of neglect, drug exposure, and failure to visit can support that finding.

In the Interest of G.M. and A.M., Children v. the State of Texas · filed 2023-05-25(b)(2)

Having reviewed the evidence in the light most favorable to the best-interest finding, we conclude that the trial court reasonably could have formed a firm belief or conviction that termination of Mother’s parental rights was in the children’s best interest because the trial court could have chosen to believe the testimony of Grandmother and the other witnesses.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a finding against termination may be reversed if it is factually insufficient.

N. N. and Texas Department of Family and Protective Services v. C. P. and J. N. · filed 2023-06-07(b)(2)

Because the evidence was factually insufficient (but otherwise legally sufficient) for the trial court to find against the Department on “best interest” for terminating parental rights, and because N.N. argues that we need not reach her second appellate issue if we sustain her first, we reverse and remand for a new trial without addressing the second issue.

Section 161.001(b)(2) requires proof that termination is in the child’s best interest in addition to a statutory predicate ground; an adverse best-interest finding may be reversed for factual insufficiency.

K. L., E. L. and Texas Department of Family and Protective Services v. C.P. and S.L. · filed 2023-06-07(b)(2)

We hold that the evidence was legally sufficient but factually insufficient for the trial court to have found that termination of Father’s and Mother’s parental rights was not in K.L.’s and E.L.’s best interest, i.e., the trial court’s failure to form a firm conviction or belief that Father’s and Mother’s parental rights should be terminated is contrary to the overwhelming weight of the evidence and clearly wrong.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; unaddressed drug use and failure to complete ordered services can support that finding.

In the Interest of N.T.P. Children v. the State of Texas · filed 2023-06-07(b)(2)

We conclude a reasonable factfinder could have formed a firm belief or conviction that termination ... of Mother’s parental rights was in the children’s best interest.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of D.L.R., Jr., D.L.W.R., and D.L.L.R., Children v. the State of Texas · filed 2023-06-07(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. ... Accordingly, we hold the evidence is legally and factually sufficient to support the trial court’s best-interest findings.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; substance exposure, unsafe housing, and unmet medical needs can support that finding.

In the Interest of K.S. and L.M., Children v. the State of Texas · filed 2023-06-08(b)(2)

Considering the record as it relates to the actions of the mother and the father, the children being exposed to marihuana and cocaine while in the parents’ care, the emotional and physical danger to the children now and in the future, the desires of the children (who were too young to express any desire), the emotional and physical needs of the children now and in the future, the parental abilities of those involved, and the plans for the children by the Department, we hold that the evidence is legally and factually sufficient to support (1) the finding that termination of the mother’s parental rights is in the best interest of the children and (2) the finding that termination of the father’s parental rights is in the best interest of L.M.

Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of E.A.R., E.A.R., E.A.R. and E.A.R., Children v. the State of Texas · filed 2023-06-21(b)(2)

In considering all the evidence in the light most favorable to the finding, we hold the trial court could have reasonably formed a firm belief or conviction that its best-interest finding was true.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s drug use, domestic violence, failure to complete services, and the children’s stability in adoptive placements may support that finding.

In the Interest of B.R.S., A.M.S., M.R.S., N.J.S., M.A.S., and L.R.S., Children v. the State of Texas · filed 2023-06-28(b)(2)

A parent-child relationship may be terminated pursuant to section 161.001 of the Texas Family Code only if the Department proves by clear and convincing evidence one of the predicate grounds enumerated in subsection (b)(1) and termination is in a child’s best interest. ... Thus, when looking at all the evidence in the light most favorable to the finding as well as in light of the entire record, we conclude the evidence is legally and factually sufficient to support the trial court’s finding termination of R.S.’s parental rights is in the children’s best interest.

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 unstable home can support that finding.

In the Interest of G.M., a Child v. the State of Texas · filed 2023-06-29(b)(2)

We review the whole record to decide whether a factfinder could reasonably form a firm conviction or belief that the Department proved that the termination of the parent–child relationship would be in the child’s best interest. Tex. Fam. Code Ann. § 161.001(b)(2); In re C.H., 89 S.W.3d 17, 28 (Tex. 2002). ... 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 G.M. was in his best interest.

Section 161.001(b)(2) requires a best-interest finding to terminate parental rights, which evidence of endangerment, drug abuse, and a child’s progress in another placement can support.

A. B. v. Texas Department of Family and Protective Services · filed 2023-07-11(b)(2)

Because of the overwhelming evidence of endangerment, including from the history of drug abuse and parenting deficiencies, and evidence of Child’s significant progress under Grandparents’ care, the evidence when viewed through the best-interest factors was legally and factually sufficient to support the trial court’s best-interest finding.

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.J.C. and C.C., Children v. the State of Texas · filed 2023-08-09(b)(2)

A judgment terminating parental rights pursuant to section 161.001 of the Texas Family Code must be supported by clear and convincing evidence of one of the predicate grounds enumerated in subsection (b)(1) and a best interest finding. ... Accordingly, we hold the evidence is legally and factually sufficient to support the trial court’s best interest finding.

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.S.R., J.A.L., and P.L., Children v. the State of Texas · filed 2023-08-09(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 is in the children’s best interests.

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 inability to meet the children’s needs can support that finding.

In the Interest of J.R.D-A, Jr., I.R.D-A, E.R.D-A, Children v. the State of Texas · filed 2023-08-09(b)(2)

We therefore hold legally and factually sufficient evidence supports the trial court’s best interest finding, and we overrule Mother’s arguments to the contrary.