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.G., a Child v. the State of Texas · filed 2023-08-10(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 Father’s parental rights is in the best interest of E.G.

A best-interest finding supporting termination is sufficient when the evidence permits a reasonable factfinder to form a firm belief or conviction that termination serves the children’s best interest.

In Re J.O.A., N.N.A., H.H.A.,A.R.L.L., M.A.L.L., Children v. . · filed 2023-08-16(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 M.R.’s parental rights was in the best interest of her children.

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

In the Interest of B. B. N., a Child v. the State of Texas · filed 2023-08-23(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 D.N.’s parental rights is in B.B.N.’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; a favorable foster placement and limited evidence of a parent’s outbursts may be insufficient.

M. L. v. Texas Department of Family and Protective Services · filed 2023-08-24(b)(2)

Even viewing such evidence in the light most favorable to the trial court’s finding, and disregarding the evidence that a factfinder could reasonably have found to be not credible—such as Mother’s representation that she would more appropriately handle stressful situations and parenting challenges in the future—we nonetheless cannot conclude that the evidence is such as to permit a reasonable factfinder to form a firm belief or conviction that termination of Mother’s parental rights is in Child’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 drug use, repeated incarceration, and inability to provide a stable home can support that finding.

In the Interest of A.B. and A.R., Children v. the State of Texas · filed 2023-08-31(b)(2)

Based on our exacting review of the entire record and weighing all of the disputed evidence, A.C., 560 S.W.3d at 631, we conclude that a reasonable factfinder could have formed a firm belief or conviction that termination was in Abigail’s and Andrew’s best interest.

Evidence of drug exposure, unstable housing and income, and limited use of available services can support the best-interest finding required for termination.

In the Interest of E.E., a Child v. the State of Texas · filed 2023-08-31(b)(2)

We conclude factually sufficient evidence supports the trial court’s best-interest finding. As such, the evidence is legally sufficient as well.

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

In the Interest of S.M.M., a Child v. the State of Texas · filed 2023-09-11(b)(2)

Mother’s issues challenge the trial court’s best interest findings under subsection 161.001(b)(2). ... Here, there is no such favorable evidence; instead, the evidence tends to rebut the presumption that the children’s best interest will be served by remaining in Mother’s custody. We conclude “the evidence is such that a factfinder could reasonably form a firm belief or conviction about the truth of the State’s allegations,” and accordingly, the evidence was legally and factually sufficient to support the trial court’s judgment.

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

In the Interest of N.C., a Child v. the State of Texas · filed 2023-09-14(b)(2)

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

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.D.M., a Child v. the State of Texas · filed 2023-09-20(b)(2)

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

A definite adoption plan is not required to establish that termination is in a child’s best interest.

In the Interest of A. R. a Minor v. Department of Family and Protective Services · filed 2023-06-27(b)(2)

While evidence of placement plans and adoption are certainly relevant to a best interest analysis, a lack of evidence about definitive plans for permanent placement and adoption cannot be the dispositive factor.

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 2023-09-29(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 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 J. S. R., a Child v. the State of Texas · filed 2023-10-25(b)(2)

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

A parent’s substance use, failure to complete services, and prolonged absence from the child’s life can support a finding under subsection (b)(2) that termination is in the child’s best interest.

In the Interest of L.W., a Child v. the State of Texas · filed 2023-10-27(b)(2)

Based on this record and applying the clear and convincing evidence standard, we find that a fact-finder could reasonably form a firm belief or conviction that termination of Mother’s parental rights was in the best interest of L.W.

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

In the Interest of E.J.C., M.J.J.C., V.P., A.N.B., and D.A.P., Children v. the State of Texas · filed 2023-11-08(b)(2)

Having reviewed the record and considered all the evidence in the appropriate light, we conclude the trial court could not have formed a firm belief or conviction that termination of Mother’s parental rights was in the children’s best interests.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the children’s best interest; abuse, parental instability, and a stable foster placement can support that finding.

In the Interest of R.E. and A.E., Children v. the State of Texas · filed 2023-11-16(b)(2)

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

A continuing pattern of illegal drug use can support a finding that termination is in a child’s best interest.

In the Interest of E. D., Child v. Department of Family and Protective Services · filed 2023-11-16(b)(2)

A continuing pattern of illegal drug use, however, implicates most of the Holley factors and will support a finding that termination of parental rights is in a child’s best interest.

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

In the Interest of R.M.H., Jr., I.Q.M.H., and A.S.M.H., Children v. the State of Texas · filed 2023-11-22(b)(2)

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

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 L.A.T., a Child v. the State of Texas · filed 2023-11-29(b)(2)

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

Section 161.001(b)(2) requires a best-interest-of-the-child finding to terminate parental rights, supported by clear and convincing evidence.

In the Interest of A.Q.C., a Child v. the State of Texas · filed 2023-12-06(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; evidence of domestic violence and the child’s placement may support that finding.

In the Interest of E. J. T., a Child v. the State of Texas · filed 2023-12-20(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 D.T.’s parental rights is in E.J.T.’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.

In the Interest of M.J.A., J.D.Z., and P.I.Z., Children v. the State of Texas · filed 2023-12-20(b)(2)

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.

In the Interest of Z.S., a Child v. the State of Texas · filed 2023-12-21(b)(2)

The trial court’s best-interest finding is supported by clear and convincing evidence.

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 S.R.T., Children v. the State of Texas · filed 2023-12-27(b)(2)

Accordingly, when considering M.M.’s conduct before and after the Department’s removal of the children, we hold the evidence is legally sufficient to support the trial court’s best interest finding. ... We therefore hold the evidence is also factually sufficient to support the trial court’s finding termination of M.M.’s parental rights was in her 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.H. and K.H., Children v. the State of Texas · filed 2024-01-18(b)(2)

Viewing the evidence in the light most favorable to the trial court’s best- interest findings, we hold that a factfinder could have reasonably formed a firm conviction or belief that termination of the parent–child relationship between Mother and Alexa and Kyle was in their best interests, and we therefore hold that the evidence is legally sufficient to support the trial court’s best-interest 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 A.R.P., a Child v. the State of Texas · filed 2024-01-24(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. ... In looking at all the evidence in the light most favorable to the trial court’s finding, we conclude a reasonable trier of fact could have formed a firm belief or conviction that termination of appellant’s parental rights was in A.R.P.’s best interest.

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 K.R. and G.R., Children v. the State of Texas · filed 2024-02-28(b)(2)

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 termination is in the child’s best interest.

In the Interest of M.M.S., a Minor Child v. the State of Texas · filed 2024-03-01(b)(2)

Accordingly, the evidence supporting the trial judge’s finding that termination of the parent-child relationship between Mother and the children was in the best interest of the children is both legally and factually sufficient.

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.I.H., a Child v. the State of Texas · filed 2024-03-06(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 H.P., a Child v. the State of Texas · filed 2024-03-07(b)(2)

The Due Process Clause of the United States Constitution and section 161.001 of the Texas Family Code require application of a heightened standard of clear and convincing evidence in cases involving involuntary termination of parental rights. ... We conclude that legally and factually sufficient evidence supports the district court’s determination that terminating Mother’s parental rights is in H.P.’s best interest.

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

In the Interest of G.D.B., a Child v. the State of Texas · filed 2024-03-20(b)

The record establishes by clear and convincing evidence the grounds for termination and that termination is in the child’s best interest.

Section 161.001(b)(2)’s best-interest requirement may be satisfied by evidence of domestic violence, limited visitation, and a stable adoptive placement.

In the Interest of K.A.M.J., K.D.J., and K.A.M.J., Children v. the State of Texas · filed 2024-03-21(b)(2)

Considering the evidence in the light most favorable to the trial court’s 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 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.G and O.G., Children v. the State of Texas · filed 2024-03-27(b)(2)

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

Section 161.001(b)(2) does not require separate consideration of alternatives to termination, and available alternatives do not preclude a finding that termination is in the child's best interest.

In the Interest of A.S.-V.M., a Child v. the State of Texas · filed 2024-03-28(b)(2)

However, a separate consideration of alternatives to termination is not required, and available alternatives to termination do not preclude a finding that termination is in the child's best interest.

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

In the Interest of J.C.D.Y. AKA J.Y., J.E.D.Y. AKA J.Y., M.M.D.Y. AKA M.Y., I.E.J. AKA I.J., M.D.K.G. AKA M.Y. AKA M.O.D · filed 2024-03-29(b)(2)

In a case to terminate parental rights under Texas Family Code Section 161.001, the Department must establish, by clear and convincing evidence, that (1) the parent committed one or more of the enumerated predicate acts or omissions justifying termination and (2) 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 J.W. and V.W., Children v. the State of Texas · filed 2024-03-29(b)(2)

Considering the evidence under the applicable standards of review, we conclude the evidence is legally and factually sufficient to support the trial court’s finding that termination of Father’s parental rights was in the best interest of J.W. and V.W.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; inadequate supervision and medical care, criminal history, and failure to complete services can support that finding.

In the Interest of A.A.D., a Child v. Department of Family and Protective Services · filed 2024-04-09(b)(2)

Furthermore, viewing the evidence in the record as a whole, we conclude that a reasonable fact finder could form a firm belief or conviction that termination of Mother’s parental rights was in A.A.D.’s best interest.

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 Z.B., J.B., and S.B., Children v. the State of Texas · filed 2024-04-11(b)(2)

Giving due regard to the 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 Z.B., J.B., and S.B.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; the court may consider a parent’s failure to follow a service plan and evidence of endangerment.

In the Interest of J.N., a Child v. the State of Texas · filed 2024-04-11(b)(2)

Based on this record, we conclude that the trial court properly determined that clear and convincing evidence establishes that the termination of Appellant’s parental rights is in the best interest of J.N.

Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest; a finding may be supported by evidence of unresolved substance abuse and instability despite some evidence of improvement.

In the Interest of D.S.R., a Child v. . · filed 2024-05-01(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 M. R. S., C. A. H., Children v. the State of Texas · filed 2024-05-07(b)(2)

We therefore 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 termination is in the child’s best interest.

In the Interest of S.O., a Child v. the State of Texas · filed 2024-05-09(b)(2)

Viewing the evidence in the light most favorable to the jury’s best-interest finding, we hold that a factfinder could have reasonably formed a firm conviction or belief that termination of the parent–child relationship between Father and Sam is in Sam’s best interest, and we therefore hold that the evidence is legally sufficient to support the jury’s best-interest finding.

Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest; a parent’s drug use, unstable housing, and failure to follow a service plan can support that finding.

In the Interest of K.J., a Child v. the State of Texas · filed 2024-05-14(b)(2)

Having considered the evidence, we conclude the trial court could have formed a firm belief that termination of Mother’s parental rights was in K.J.’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, failure to complete services, and inconsistent contact with the child can support that finding.

R. R. and A. C. v. Texas Department of Family and Protective Services · filed 2024-05-23(b)(2)

We conclude that the evidence is legally and factually sufficient to support the district court’s finding that termination of Father’s and Mother’s parental rights was in the best interest of Child.

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

In the Interest of G.G., a Child v. the State of Texas · filed 2024-05-30(b)(2)

Giving due deference to the trial court, as we must, we hold that, based on the evidence in the record and the application of the Holley factors, the trial court could have reasonably formed a firm belief or conviction that termination of Appellant’s parental rights was in the best interest of the child.

A parent’s conviction for sexually assaulting the child’s sibling can alone support a finding that termination is in the child’s best interest.

In the Interest of A.S., a Child v. the State of Texas · filed 2024-05-30(b)(2)

The trial court could have found termination in Aaron’s best interest on Father’s sexual-assault conviction alone.

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

In the Interest of N.M. and H.M., Children v. the State of Texas · filed 2024-06-13(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 Father’s parental rights to Neely and Holly was in their best interest.

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

In the Interest of S.P., N.I.A.D., A.D., and N.C.N.D., Children v. the State of Texas · filed 2024-06-20(b)(2)

Therefore, the evidence was legally and factually sufficient to support the trial court’s best- interest-of-the-child 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 M.J.H., Child v. the State of Texas · filed 2024-06-20(b)(2)

Therefore, the evidence was legally and factually sufficient to support the trial court’s best-interest-of-the-child finding. See TEX. FAM. CODE § 161.001(b)(2); In re J.F.C., 96 S.W.3d 256, 266 (Tex. 2002).

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

In the Interest of D.D.D., a Child v. the State of Texas · filed 2024-06-20(b)(2)

We therefore hold legally and factually sufficient evidence supports the trial court’s best interest finding, and we overrule A.D.’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 M.G., a Child v. the State of Texas · filed 2024-06-27(b)(2)

Given Marty’s injuries, the stability of his foster home, and Mother’s unsatisfactory explanations, the evidence was sufficient for the trial court to find by clear and convincing evidence that termination of Mother’s parental rights was in Marty’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 drug use, endangerment, and failure to follow a service plan may support that finding.

In the Interest of D.K.H., a Child v. the State of Texas · filed 2024-07-11(b)(2)

Thus, the trial court could properly consider Appellant’s failure to comply with the conditions of her family service plan, drug use, and other evidence of endangerment in determining whether the termination of her parental rights was in D.K.H.’s best interest.

A continuing pattern of serious illegal drug use can support a finding that termination is in a child’s best interest.

In the Interest of E.F.K., a Child v. Department of Family and Protective Services · filed 2024-07-16(b)(2)

This record constitutes clear and convincing evidence that supports the trial court’s finding that termination of the mother’s parental rights is in E.F.K.’s best interest. As we have explained in the past, when the record shows a continuing pattern of serious illegal drug use, this evidence implicates most of the Holley factors and will support a trial court’s best-interest finding in favor of termination.

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

In the Interest of R.H., a Child v. the State of Texas · filed 2024-07-16(b)(2)

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 R.H. was in the best interest of the child.

Section 161.001(b)(2) requires a best-interest finding supported by clear and convincing evidence before parental rights may be terminated.

K. M. S. v. Texas Department of Family and Protective Services · filed 2024-07-31(b)(2)

Viewing the totality of this evidence in the light most favorable to the district court’s finding, we conclude that a reasonable factfinder could form a firm belief or conviction that termination of Mother’s parental rights was in the best interest of the children. Accordingly, the evidence is legally sufficient to support the 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 A.I.R., a Child v. the State of Texas · filed 2024-08-07(b)(2)

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

A finding that termination is in the child’s best interest may be supported by evidence of a parent’s drug activity, failure to complete services, and the child’s stable placement.

In the Interest of J.H., a Child v. the State of Texas · filed 2024-08-08(b)(2)

Our review of the evidence under the appropriate standards, giving full deference to the jury’s role as factfinders, leads us to conclude that the evidence was legally and factually sufficient for the jury to have found that termination was in the best interest of J.H.

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

In the Interest of I.N., F.N., and E.N., Children v. the State of Texas · filed 2024-08-08(b)(2)

Appellant’s continuing pattern of illegal drug use, failure to comply with his service plan, and his failure to secure a safe and stable home for his children support the trial court’s best-interest finding.

Section 161.001(b)(2)’s best interest requirement can be supported by evidence of drug use, incomplete services, unstable housing, and the children’s care in a foster home.

In the Interest of I.E.P. v. the State of Texas · filed 2024-08-14(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.

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

In the Interest of K.D.R., K.D.R., and K.C.R. v. the State of Texas · filed 2024-08-15(b)(2)

We conclude the Department established, by clear and convincing evidence 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 terminating parental rights is in the child’s best interest.

In the Interest of E.A.O.E. AKA E.O.E., G.E.O.E. AKA G.O.E., Children v. the State of Texas · filed 2024-08-20(b)(2)

Viewing the evidence in the light most favorable to the judgment for our legal- sufficiency analysis and all the evidence equally for our factual-sufficiency analysis, we conclude that a reasonable fact finder could have formed a firm belief or conviction that termination of Father’s parental rights was in the children’s best interest. See Tex. Fam. Code § 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 B.J.D., a Child v. the State of Texas · filed 2024-08-21(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 R.D.’s parental rights was in the best interest of B.J.D. See TEX. FAM. CODE ANN. § 161.001(b)(2); In re J.F.C., 96 S.W.3d at 266.

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

In the Interest of Z.B., a Child v. the State of Texas · filed 2024-08-30(b)(2)

Upon considering the record as it relates to Appellant’s actions and inactions, the emotional and physical danger to the child now and in the future, the emotional and physical needs of the child now and in the future, Appellant’s parental abilities, and her positive drug tests and refusals to test, 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 the child.

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

In the Interest of C.H. and L.H., Children v. the State of Texas · filed 2024-09-19(b)(2)

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 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 S.M.O., a Child v. the State of Texas · filed 2024-09-25(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).

A best-interest finding under section 161.001 may be supported by a child’s fear of returning home, a parent’s failure to complete services, and evidence of an unstable home.

In the Interest of A.M.B., a Child v. the State of Texas · filed 2024-10-23(b)(2)

We therefore hold that legally and factually sufficient evidence supports the trial court’s best-interest finding, and we overrule A.C.S.’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 T.E., a Minor Child v. the State of Texas · filed 2024-10-31(b)(2)

Considering the evidence pertinent to each of the Holley factors, we conclude that the evidence is legally and factually sufficient to support the trial court’s finding that termination of the parent–child relationship between Father and T.E. is in T.E.’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 K.A., a Child v. the State of Texas · filed 2024-10-31(b)(2)

For a trial court to terminate a parent–child relationship, the party seeking termination must establish, by clear and convincing evidence, that (1) the parent’s actions satisfy just one of the many predicate grounds listed in Family Code Section 161.001(b)(1), and (2) termination is in the child’s best interest under Section 161.001(b)(2). ... Nevertheless, considering the evidence pertinent to each of the Holley factors, we conclude that 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 termination is in the child’s best interest.

In the Interest of Am.A.G., An.A.G., and S.L.A.G., Children v. the State of Texas · filed 2024-11-06(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)’s best-interest requirement can be met by evidence of unsafe housing, continued drug use, unmet needs, and stable foster placements despite a parent’s progress.

J. M. III and T. R. v. Texas Department of Family and Protective Services · filed 2024-11-15(b)(2)

However, we conclude under the applicable legal- and factual-sufficiency standards that the evidence as a whole allowed the trial court to form a firm belief or conclusion about the best-interest finding against Father.

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

In the Interest of L. M. C., R. C. & R. W. C., Jr., Children v. the State of Texas · filed 2024-11-20(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 D.S.’s parental rights 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 E.H. and I.H.,children v. the State of Texas · filed 2024-11-21(b)(2)

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 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 D.Y.V.M, and G.E.M., Children v. the State of Texas · filed 2024-12-05(b)(2)

Viewing the evidence in the light most favorable to the judgment for our legal-sufficiency analysis and all of the evidence equally for our factual-sufficiency analysis, we conclude that a reasonable fact finder could have formed a firm belief or conviction that termination of Mother’s parental rights was in Gema and Darby’s best interest. See Tex. Fam. Code § 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 I.J.M., L.M.M., A.F.M., and E.M.M., Children v. the State of Texas · filed 2024-12-11(b)(2)

We therefore hold the evidence is legally and factually sufficient to support the trial court’s best-interest finding.

Evidence of a parent’s alcohol use, missed visits, incomplete services, and the child’s stable foster placement can support a finding that termination is in the child’s best interest.

In the Interest of K.J.J., a Child v. the State of Texas · filed 2024-12-18(b)(2)

We therefore hold that legally and factually sufficient evidence supports the trial court’s best-interest finding, and we overrule T.J.’s arguments to the contrary.

Under § 161.001(b)(2), a parent’s drug use and failure to learn how to meet children’s special needs can support a finding that termination is in their best interest.

In the Interest of J.L.R. and P.J.R., Children v. the State of Texas · filed 2024-12-23(b)(2)

Therefore, 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 J.A.T., a Child v. the State of Texas · filed 2024-12-23(b)(2)

Therefore, 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 termination is in the child’s best interest; parental conduct, the child’s needs, and placement stability may support that finding.

In the Interest of D.A.C.R., a Child v. the State of Texas · filed 2024-12-23(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 terminating parental rights is in the child’s best interest.

In the Interest of R.E.C. and O.S.H.T., Children v. the State of Texas · filed 2025-01-29(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 A.C. and A.S.L.C., Children v. the State of Texas · filed 2025-02-05(b)(2)

The record before us therefore demonstrates sufficient evidence to support the trial court’s finding that termination is in the best interest of the children.

The availability of alternatives to termination does not prevent a finding that termination is in a child’s best interest, and those alternatives need not be considered separately.

In the Interest of T.E. and M.E., Children v. the State of Texas · filed 2025-02-06(b)(2)

However, the existence of alternatives to termination does not preclude a finding that termination is in the child's best interest, and a separate consideration of available alternatives to termination is not required.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest, and recent parental improvement need not outweigh evidence of neglect and danger.

In the Interest of S.D.G. A/K/A S.D.R.S.G., a Child v. the State of Texas · filed 2025-02-06(b)(2)

Looking at all of the evidence in the light most favorable to the trial court’s finding, we conclude a reasonable trier of fact could have formed a firm belief or conviction that termination was in S.D.G.’s best interest. See TEX. FAM. CODE ANN. § 161.001(b)(2); In re A.C., 560 S.W.3d at 630.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest, even when the parents have completed their services.

In the Interest of G.J., a Child v. the State of Texas · filed 2025-02-06(b)(2)

Applying the evidence to the relevant factors, we conclude that although the parents produced evidence in their favor, clear and convincing 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 K.G.Jr., a Child v. the State of Texas · filed 2025-02-13(b)(2)

We conclude 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 the child.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a best-interest finding may be upheld when the evidence of danger and instability outweighs evidence of a loving parent-child bond.

A. P. v. Texas Department of Family and Protective Services · filed 2025-02-20(b)(2)

After weighing the disputed evidence that is contrary to the best-interest finding against the evidence supporting the best-interest finding, we conclude that the disputed evidence is not so significant that a reasonable factfinder could not have resolved it in favor of the finding. Accordingly, after considering the relevant factors under the appropriate standard of review, we conclude that the evidence is factually sufficient to support the trial court’s finding that termination of the parent-child relationship was in J.P.’s best interest.

A parent’s refusal to submit to drug testing may support an inference of continued drug use when determining whether termination is in a child’s best interest.

In the Interest of E.M., I.M., W.M., E.M., M.M., Children v. the State of Texas · filed 2025-02-27(b)(2)

A parent’s refusal to submit to drug testing permits the inference that he or she is continuing to abuse drugs, which is properly considered in determining whether termination is 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.

In the Interest of M.W., a Child v. the State of Texas · filed 2025-02-28(b)(2)

Considering the Holley factors, and in light of all of the evidence, the trial court could have reasonably formed a firm belief or conviction that termination of Father’s parental rights was in Marshall’s best interests. Therefore, we conclude that the evidence was legally and factually sufficient to support the best-interest finding, and we overrule Father’s last point of error.

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.B.M.M., a Child v. the State of Texas · filed 2025-03-05(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 termination is in the child’s best interest.

In the Interest of L.I., a Child v. the State of Texas · filed 2025-03-06(b)(2)

Even considering that Lacy was too young to express her desires and that the record contained little evidence about programs available for Mother, we nevertheless 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; continued exposure to domestic violence can support that finding.

In the Interest of E.J.C.T., a Child v. the State of Texas · filed 2025-03-19(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 E.J.C.T.’s best interest.

Section 161.001(b)(2) requires sufficient evidence that termination is in the child’s best interest, even when a ground for termination has been proved.

In the Interest of A.C.P, A.I.P, A.M.P., M.J-R.P. III, and M.C.S., Children v. the State of Texas · filed 2025-03-25(b)(2)

Therefore, we hold there was legally insufficient evidence 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 children’s best interest.

In the Interest of D.S.D. Jr., D.D.III, D.M.D., Children v. Department of Family and Protective Services · filed 2025-03-25(b)(2)

Viewing the evidence in the light most favorable to the trial court’s finding, we conclude that the trial court could 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. See 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 L.J.C., a Child v. the State of Texas · filed 2025-03-26(b)(2)

Therefore, we hold the evidence is legally and factually sufficient to support the jury’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; persistent drug use and the child’s progress in a stable placement can support that finding.

In the Interest of J.T.R.W., a Child v. the State of Texas · filed 2025-03-26(b)(2)

Mindful that the best-interest inquiry is “child-centered” and focusing on J.T.R.W.’s “well-being, safety, and development,” 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 termination is in the child’s best interest; parental endangerment, drug use, instability, and the child’s improvement in a stable placement can support that finding.

In the Interest of S.B., a Child v. the State of Texas · filed 2025-03-27(b)(2)

We conclude that the evidence is legally and factually sufficient to support the trial court’s finding that termination of Appellants’ parental rights is in the best interest of S.B.

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

In the Interest of M.H., S.H., and B.H., Children v. the State of Texas · filed 2025-03-27(b)(2)

In parental termination cases, the Department must prove two elements by clear and convincing evidence: (1) the parent’s actions satisfy a statutory ground under Section 161.001(b)(1); and (2) termination is in the child’s best interest. ... Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s best-interest finding, and 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 A.W., M.B. and J.B., Children v. the State of Texas · filed 2025-04-03(b)(2)

Considering all the best-interest factors, we conclude that the evidence is legally and factually sufficient to support the trial court’s best-interest finding.

Section 161.001(b)(2)'s best-interest finding may be supported by a parent's continued illegal drug use, failure to complete services, and inability to provide a stable home.

In the Interest of K.B., a Child v. the State of Texas · filed 2025-04-10(b)(2)

We conclude that the trial court reasonably could have formed a firm belief or conviction that termination of Father’s parental rights was in K.B.’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 K.D., a Child v. the State of Texas · filed 2025-04-10(b)(2)

The record contains sufficient evidence to allow a reasonable factfinder to form a firm belief or conviction that termination of Mother’s and Father’s parental rights to K.D. was in K.D.’s best interest.

Section 161.001(b)(2) permits a best-interest finding even when the Department may be unable to place the children for adoption.

In the Interest of E.A., C.A., L.A., and E.A., Children v. the State of Texas · filed 2025-04-10(b)(2)

Consequently, even when the Department may not be able to place the children for adoption, termination may nevertheless be 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 E.M v. and G.R.R., Children v. the State of Texas · filed 2025-04-30(b)(2)

Turning to factual sufficiency, we further conclude that when viewing the entire record, any evidence contrary to the finding is not so significant that it would prevent a reasonable factfinder from forming the same firm belief or conviction termination was in the children’s best interest. See J.F.C., 96 S.W.3d at 266; TEX. FAM. CODE § 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 E.M.T., J.A.T., E.C.S., E.M.S., E.D.S., and E.A.C., Children v. the State of Texas · filed 2025-05-07(b)(2)

Therefore, 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 terminating parental rights is in the child’s best interest.

In the Interest of H.E.B., a Child v. the State of Texas · filed 2025-05-14(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; evidence of endangerment, substance abuse, and instability can support that finding.

In the Interest of B.C., a Child v. the State of Texas · filed 2025-05-22(b)(2)

Based on the trial evidence, the trial court had factually sufficient evidence that termination was in Braxton’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.B., S.B. and J.B., Children v. the State of Texas · filed 2025-06-26(b)(2)

However, considering all the evidence here in the light most favorable to the trial court’s finding and considering the evidence as a whole, we hold that a reasonable factfinder could have formed a ... firm belief or conviction that termination of Father’s parental rights was in the children’s best interest.

Subsection (b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s criminal history and ability to care for the child may support that finding.

In the Interest of L.C., a Child v. the State of Texas · filed 2025-06-26(b)(2)

Here, the evidence is legally and factually sufficient to show that termination of Father’s parental rights to L.C. is 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; continued drug use and a stable adoptive placement can support that finding despite recent treatment progress.

In the Interest of O.J.G. and O.E.G., Children v. the State of Texas · filed 2025-07-10(b)(2)

And when viewing all of the evidence in the light most favorable to the trial court’s finding, we conclude a reasonable trier of fact could have formed a firm belief or conviction that termination was in the children’s best interest. See TEX. FAM. CODE ANN. § 161.001(b)(2); In re A.C., 560 S.W.3d at 630.

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

In the Interest of A.P. and J.P., Children v. the State of Texas · filed 2025-07-22(b)(2)

Because we find that the trial court’s best-interests finding was supported by legally and factually sufficient evidence, we affirm the trial court’s judgment.

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

In the Interest of L.D., a Child v. the State of Texas · filed 2025-07-23(b)(2)

Having reviewed the record and considered all the evidence under the appropriate standards of review, and given that these factors weigh in favor of termination, we conclude the trial court could have formed a firm belief or conviction that termination of Mother’s parental rights was in the child’s best interest.

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 L.R., a Child v. the State of Texas · filed 2025-08-07(b)(2)

Accordingly, we hold that the evidence is both legally and factually sufficient to support the trial court’s finding that termination is in L.R.’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 E.S.-A. and A.S.-A., Children v. the State of Texas · filed 2025-08-18(b)(2)

Assuming, without deciding, the Department provided clear and convincing evidence of predicate grounds (N), (O), or both, it did not demonstrate by that same standard that termination of Mother’s parental rights to her two younger daughters was in the children’s best interests. With an insufficient best-interest finding, the termination order fails.

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

In Re L.C.A.S., C.L.S., K.C.C., Children v. the State of Texas · filed 2025-08-20(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 interests.

Section 161.001(b)(2) requires a finding that termination is in the child’s best interest; continued drug use and a stable prospective adoptive home can support that finding.

In the Interest of E.K.M., a Child v. the State of Texas · filed 2025-08-21(b)(2)

Viewing the evidence in the requisite light, we conclude that both legally and factually sufficient evidence support the trial court’s firm conviction and belief that termination of AM’s parental rights was in EKM’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 M.R., L.R., E.R., H.R., V.R., Children v. the State of Texas · filed 2025-09-25(b)(2)

Before parental rights may be involuntarily terminated, the trier of fact must find two elements by clear and convincing evidence: (1) that the parent committed one of the statutory grounds for termination found in § 161.001(b)(1) of the family code; and (2) that termination is in the child’s best interest. ... Looking at all of the evidence in the light most favorable to the trial court’s finding, we conclude a reasonable trier of fact could have formed a firm belief or conviction that termination 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 R.J.R., a Child v. the State of Texas · filed 2025-10-01(b)(2)

Having reviewed the record and considered all the evidence under the appropriate standard of review and given that these factors weigh in favor of termination, we conclude the trial court could have formed a firm belief or conviction that termination of Mother’s parental rights was in the child’s best interests. See TEX. FAM. CODE § 161.001(b)(2); H.R.M., 209 S.W.3d at 108; J.P.B., 180 S.W.3d at 573.

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 J.P., a Child v. the State of Texas · filed 2025-10-16(b)(2)

After viewing all of the evidence in the light most favorable to the best-interest finding, we conclude that the evidence was sufficiently clear and convincing such that a reasonable fact- finder could have formed a firm belief or conviction that termination of the parent-child relationship between Mother and Jimmy was in the child’s best interests.

Section 161.001(b)(2) requires a best-interest finding to terminate parental rights; evidence of abuse, unmet medical needs, living arrangements, and a child’s progress in foster care may support that finding.

In the Interest of D.M., a Child v. the State of Texas · filed 2025-10-27(b)(2)

We find the evidence is 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.

R. C. v. Texas Department of Family and Protective Services · filed 2025-10-30(b)(2)

A court may order the termination of the parent-child relationship only if it is shown by clear and convincing evidence that termination is in the child’s best interest. Tex. Fam. Code § 161.001(b)(2). ... We conclude that the evidence was legally and factually sufficient to support the trial court’s best-interest finding, and we overrule Richard’s sole issue on appeal.

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 V.A. and L.A., Children v. the State of Texas · filed 2025-11-26(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 proof that terminating parental rights is in the child’s best interest.

In the Interest of M.A.T.T., a Child v. the State of Texas · filed 2025-12-10(b)(2)

Having reviewed the record and considered all the evidence under the appropriate standard of review and given that these factors weigh in favor of termination, we conclude the trial court could have reasonably formed a firm belief or conviction that termination of Father’s parental rights was in the child’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 M.C. and J.R. v. the State of Texas · filed 2025-12-11(b)(2)

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

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest, in addition to proof of a ground for termination.

In the Interest of M.B.-O., B.B.-O., D.B.-O., and J.B.-O., Children v. the State of Texas · filed 2025-12-11(b)(2)

With proof of one or more of the grounds for termination, the trial court may order termination of the parent–child relationship only if the factfinder also finds by clear and convincing evidence that termination is in the best interest of the child. 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 B.H., a Child v. the State of Texas · filed 2026-01-21(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 B.H.’s best interest.

Section 161.001(b)(2)’s best-interest finding can be supported by evidence of continued drug use, inconsistent visits, incomplete services, and a stable placement even when agency records are missing.

In the Interest of H.F.F. and S.S.F., Children v. the State of Texas · filed 2025-12-23(b)(2)

We conclude the evidence is legally and factually sufficient to support the trial court’s finding that termination was in the best interest of the children. ... We affirm the termination order based on the uncontested predicate findings and the best-interest finding under § 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 T.L.K., Jr., S.M.C., and S.B.C., Children v. the State of Texas · filed 2026-02-11(b)(2)

As future conduct may be inferred from past conduct, we conclude the trial court could have reasonably formed a firm belief or conviction that termination of his parental rights was in his children’s best interest.

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

In the Interest of J.S. v. the State of Texas · filed 2026-02-11(b)(2)

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

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the children’s best interest, and persistent parental drug use may support that finding.

In the Interest of T.B., K.B., T.B., K.B., Children v. the State of Texas · filed 2026-02-12(b)(2)

Considering the evidence as it relates to each parent’s actions and inactions, the emotional and physical danger to the children now and in the future, the emotional and physical needs of the children now and in the future, each parent’s lack of parental abilities and stability, and each parent’s criminal conduct and drug use, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that termination of each parent’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 a child’s best interest; endangerment, parental indifference, and stable adoptive placements can support that finding.

In the Interest of K.H., K.A., K.A., Children v. the State of Texas · filed 2026-02-27(b)(2)

Giving the requisite due deference to the trier of fact, we hold that, based on the evidence in the record and the application of the Holley factors, the trial court could have formed a firm belief or conviction that termination of Appellant’s parental rights was in the best interest of K.A. and K.A.2.

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

In the Interest of A.M, L.M., A.M., M.M., Children v. the State of Texas · filed 2026-02-27(b)(2)

Giving the requisite due deference to the trier of fact, we hold that, based on the evidence in the record and the application of the Holley factors, the jury could have formed a firm belief or conviction that termination of each parent’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 I.R.D. and C.R.D., Children v. the State of Texas · filed 2026-03-04(b)(2)

To terminate parental rights pursuant to Family Code 161.001, 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 child’s best interest. ... We therefore hold the evidence is legally and factually sufficient to support the trial court’s best interest findings and overrule Mother’s and Father’s sole point of error.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; competing evidence on that issue can preclude summary judgment.

D. L. J. v. M. D. S. · filed 2026-03-06(b)(2)

Based on this and other evidence summarized above, we cannot conclude, as a matter of law, that there is clear and convincing evidence that termination of Father’s parental rights is in Sarah’s best interest. After weighing the competing evidence provided by the parties, a factfinder could ultimately conclude that there is, but that should occur following a trial, not on summary judgment.

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

In the Interest of J.E.H., a Child v. the State of Texas · filed 2026-03-25(b)(2)

Considering the applicable factors and the evidence before us, we find 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 J.E.H.’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 E.D.A., Child v. the State of Texas · filed 2026-03-25(b)(2)

Therefore, 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 termination is in the children’s best interest, taking account of the parent’s improvement as well as past endangerment.

In the Interest of M.L. and E.L., Children v. the State of Texas · filed 2026-03-26(b)(2)

Considering all the evidence as it relates to Appellant’s actions and inactions, the absence of evidence indicating emotional and physical danger to the children now and in the future, Appellant’s ability to meet the emotional and physical needs of the children now and in the future, and Appellant’s efforts and improved parental abilities and stability, we hold that the evidence is insufficient to support the trial court’s finding that termination of Appellant’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.

In the Interest of J.D., R.D.-G., K.G., and L.G., Children v. the State of Texas · filed 2026-03-26(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 Father’s parental rights to Roger, Kenneth, and Lacy was in their best interest.

Section 161.001(b)(2)'s best-interest requirement may be satisfied by evidence of a parent's drug use and a stable foster placement with a prospective adoptive family.

In the Interest of B.G.A.Y., a Child v. the State of Texas · filed 2026-04-09(b)(2)

Considering all the Holley factors, we conclude that the evidence was legally and factually sufficient to rebut the presumption that keeping the child with her biological mother is in her best interest.

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

In the Interest of R.H. and E.H., Children v. the State of Texas · filed 2026-04-16(b)(2)

Upon considering the evidence as it relates to Appellant’s actions and inactions, the emotional and physical danger to the children now and in the future, the emotional and physical needs of the children now and in the future, Appellant’s lack of parental abilities and stability, and Appellant’s history of drug use, 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 the children.

Section 161.001(b)(2) requires clear and convincing evidence that termination is in the child’s best interest; a parent’s instability, untreated mental-health issues, drug use, and failure to comply with a service plan can support that finding.

In the Interest of B.G.T. AKA E.T., a Child v. the State of Texas · filed 2026-04-21(b)(2)

As such, after an exacting review of the record, we find that a fact-finder could reasonably have concluded that Mother’s lack of stability, untreated mental-health issues, drug use, and failure to comply with her service plan supported the finding that termination was in E.T.’s best interest.

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

In the Interest of E.M.M Jr., N.M.M., N.J.M., I.A.M., M.S.R., A.L.M., Children v. the State of Texas · filed 2026-04-29(b)(2)

After reviewing the evidence under the appropriate standards 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.

Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the children’s best interest; repeated drug exposure and unsafe parental conduct can support that finding.

In the Interest of E.T., E.T., E.T., E.D., Children v. the State of Texas · filed 2026-04-30(b)(2)

Upon considering the evidence as it relates to each parent’s actions and inactions, the emotional and physical danger to the children now and in the future, the emotional and physical needs of the children now and in the future, the mother’s history of drug use, and each parent’s drug-related criminal history, we hold that the evidence is legally and factually sufficient to support the trial court’s findings that termination of each parent’s parental rights is in the best interest of their respective children.

Section 161.001(b)(2) requires clear and convincing evidence that terminating parental rights is in the child’s best interest; a parent’s conduct, the child’s needs, and risks to the child can support that finding.

In the Interest of C.F., a Child v. the State of Texas · filed 2026-04-30(b)(2)

Considering Appellant’s acts and omissions, the emotional and physical danger to C.F. now and in the future, the emotional and physical needs of C.F. now and in the future, Appellant’s criminal history, and his history of drug use, 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 C.F.’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 K.M.N., P.N. III, E.J.N., I.A.N., B.L.N., C.A.N., S.V.N., L.F.N., and S.N., Children v. Department of · filed 2026-05-07(b)(2)

We conclude the Holley factors support 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.

In the Interest of D.W., A.W., B.S.D, and T.G., Children v. the State of Texas · filed 2026-05-21(b)(2)

Giving the requisite due deference to the trier of fact, we hold that, based on the evidence in the record and the application of the Holley factors, the trial court could have formed a firm belief or conviction that termination of each parent’s parental rights was in the best interest of the children.

Section 161.001(b)(2) requires an independent finding that termination is in the child’s best interest, even when a ground under subsection (b)(1) is proved.

In the Interest of H.S., B.S., and M.S., Children · filed 2026-06-05(b)(2)

Section 161.001(b)(2) imposes a separate best-interest requirement with independent force, and it is not automatically satisfied just because a parent committed one of the acts enumerated in subsection (b)(1).

Section 161.001(b)(2) requires clear and convincing evidence that ending the parent-child relationship is in the child’s best interest; evidence that the parent is not ready for custody alone is insufficient.

In the Interest of A.A. a Child v. Department of Family and Protective Services · filed 2026-06-11(b)(2)

While these aspects may demonstrate that Mother is not ready to have custody of A.A., a reasonable factfinder could not have formed a firm belief or conviction that termination of Mother’s rights—meaning she will have no relationship with A.A. at all—was in A.A.’s best interest.

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

In the Interest of A.D., S.R., and K.A., Children v. the State of Texas · filed 2026-06-18(b)(2)

Upon considering the emotional and physical danger to the children now and in the future, the emotional and physical needs of the children now and in the future, Appellant’s actions and inactions, drug use, criminal history, history with the Department, and refusal to address the issues that caused the Department’s years of involvement, we hold that the evidence is legally and factually sufficient to support the trial court’s findings that termination of Appellant’s parental rights is in the best interest of the children.

Section 161.001(2) requires a separate inquiry into the child’s best interest even when a ground for termination exists.

John Koo Hyun Kim v. United Central Bank and Texas Department of Banking · filed 2007-06-15(2)

The dissent’s approach would mean that once a parent commits an act permitting termination, there is no need to conduct further inquiry into best interest, something section 161.001(2) specifically requires.

Section 161.001 requires proof of a listed termination ground and proof that termination is in the child's best interest.

in the Interest of M.P. and J.P., Children · filed 2010-12-23(2)

In proceedings to terminate the parent-child relationship brought under section 161.001 of the family code, the petitioner must establish one ground listed under subdivision (1) of the statute and must also prove that termination is in the best interest of the child.

Section 161.001(b) requires a statutory ground for termination and a finding that termination is in the child’s best interest.

In the Interest of R.R.G. IV, a Child v. the State of Texas · filed 2023-07-06(b)

To terminate parental rights, a court must find one of the grounds for termination specified in § 161.001(b)(1) of the family code 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; a best-interest finding need not be supported by every Holley factor.

In the Interest of A.S. and D.S., Children v. the State of Texas · filed 2023-11-09(b)(2)

A court may terminate a parental relationship if it finds by clear and convincing evidence (1) one or more statutory grounds for termination and (2) that termination is in the child’s best interest. TEX. FAM. CODE § 161.001(b)(1)–(2).

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

in the Interest of M.A. and M.A., Jr., Children · filed 2001-07-12(1)(E)

However, if the evidence, including imprisonment, shows a course of conduct which has the effect of endangering the physical or emotional well-being of the child, a finding under section 161.001(1)(E) is supportable.