Tex. Fam. Code Ann. § 161.001

The evidence supported a finding that the parent knowingly exposed the child to endangering surroundings under subsection (1)(D).

in the Int of JJB, a Child · filed 2014-08-27(1)(D)

We hold the evidence was sufficient for a reasonable trier of fact to have formed a firm belief or conviction that James knowingly placed or knowingly allowed J.J.B. to remain in conditions or surroundings that endangered his physical or emotional well-being.

Section 161.001(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed a child in conditions or surroundings that endangered the child’s physical or emotional well-being.

J. E. and B. K. v. Texas Department of Family and Protective Services · filed 2014-09-10(1)(D)

Considering the evidence in the light most favorable to the jury’s finding, we find that a jury could reasonably have formed a firm conviction that Jessica knowingly placed G.K. in an environment which endangered her physical or emotional well-being.

The evidence supported a finding that the parent knowingly placed the children in endangering surroundings under subsection (1)(D).

B. C. v. Texas Department of Family and Protective Services · filed 2014-10-08(1)(D)

This evidence standing alone is sufficient to support the trial court’s finding that Appellant knowingly placed or allowed the children to remain in conditions or surroundings which endangered their physical or emotional well-being under subsection 161.001(1)(D).

The evidence legally and factually supported termination under subsection (1)(D).

in the Interest of A.J.R., E.J.R.H. and K.M.J.H., Children · filed 2014-12-01(1)(D)

The evidence is legally and factually sufficient to support the trial court’s finding as to each parent under Section 161.001(1)(D).

The evidence established a subsection (1)(D) ground and the children’s best interest by clear and convincing evidence.

in the Interest of G.L.K., M.R.T., and E.A.M. · filed 2014-12-11(1)(D)

We conclude that the Department established, by clear and convincing evidence, that appellant committed the predicate act enumerated in section 161.001(1)(D) and that termination is in the children’s best interest.

Section 161.001(1)(D) concerns a child’s living environment, and a parent’s conduct may be relevant to whether that environment endangers the child.

L. R. v. Texas Department of Family and Protective Services · filed 2014-12-11(1)(D)

Subsection (D) concerns the child’s living environment, rather than the parent’s conduct, though parental conduct is relevant to the child’s environment.

Under subsection (1)(D), later cleaning of a home does not erase a child’s earlier exposure to endangering conditions.

in the Int of R.V.M., N.M., M.B.R.C, R.A.R.C. and S.R.R.C. · filed 2015-01-21(1)(D)

Although there was evidence that Manuel eventually cleaned up the home, this does not controvert the evidence that Roseanna and Manuel previously had exposed the children to an environment endangering their well-being.

Section 161.001(1)(D) requires the child's environment to be the source of endangerment to the child's physical or emotional well-being.

in the Interest of P.M., the Child · filed 2015-01-01(1)(D)

Under subsection (D), we must examine evidence related to the child’s environment to determine if the environment was the source of endangerment to the child’s physical or emotional well-being.

Section 161.001(1)(D) permits termination when the evidence supports a firm belief that a parent knowingly placed or allowed a child to remain in endangering surroundings.

in the Interest of Z.L.M. · filed 2015-02-05(1)(D)

The trial court could reasonably have formed a firm belief or conviction that appellant knowingly placed or knowingly allowed Z.L.M. to remain in conditions or surroundings which endangered her physical or emotional well-being.

Section 161.001(1)(D) permits termination when a parent knowingly allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

W. D. and B. D. v. Texas Department of Family and Protective Services · filed 2015-02-05(1)(D)

Based on this evidence alone, the jury could have reasonably found that Walter Sr. knowingly allowed Walter Jr. to remain in conditions or surroundings that endangered Walter Jr.’s physical and emotional well-being.

Section 161.001(1)(D) permits termination when clear and convincing evidence shows a parent knowingly placed or allowed a child to remain in conditions or surroundings that endangered the child’s physical or emotional well-being.

in the Interest of J.J.S., a Child · filed 2015-02-25(1)(D)

Roxanne G.’s criminal history, her drug abuse before and after the incident leading to the removal of J.J.S., and the actual incident leading to J.J.S.’s removal constitute legally and factually sufficient evidence to support the trial court’s finding under section 161.001(1)(D).

Section 161.001(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in surroundings that endanger the child's physical or emotional well-being.

in the Interest of M.R.H., a Child · filed 2015-05-26(1)(D)

We conclude that the evidence, viewed in the light most favorable to the trial court’s finding, was sufficiently clear and convincing that a reasonable factfinder could have formed a firm belief or conviction the mother knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endangered her child’s physical or emotional welfare.

Section 161.001(1)(D) permits termination based on a single act or omission by a parent.

in the Interest of M.C. and T.C., Children · filed 2015-06-12(1)(D)

Subsection D permits termination based on a single act or omission by the parent.

The court found the mother’s drug use and exposure of her children to domestic violence sufficient to support statutory termination grounds.

in the Interest of M.J.A.G. · filed 2015-08-12(1)(D)

The evidence demonstrated Mother’s drug use impaired her ability to provide care for her children. Mother testified she would have Rosa J. babysit the children when she used drugs. Mother also admitted she exposed A.T.L.G. and D.R.G. to domestic violence. This evidence is sufficient to support the statutory grounds of the trial court’s termination of Mother’s parental rights.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows children to remain in surroundings that endanger their physical or emotional well-being.

in the Interest of K.G., a Minor · filed 2015-09-08(b)(1)(D)

Similarly, we conclude a reasonable factfinder could have formed a firm belief or conviction that Mother knowingly allowed the children to remain in conditions or surroundings which endangered the physical and emotional well-being of the children because she denied all ... allegations of violence by Father, continued to live with him and eventually married him, and told the Department that she had to have his help.

The court upheld a subsection (1)(D) termination finding after finding the evidence legally and factually sufficient.

in the Interest of S.H., a Child · filed 2015-07-01(1)(D)

We hold the evidence is legally and factually sufficient to support the trial court’s finding that termination of R.G.’s parental rights to S.H. was warranted pursuant to Section 161.001(1)(D).

Section 161.001(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions endangering the child’s physical or emotional well-being.

in the Interest of O.R.W. · filed 2015-08-13(1)(D)

Accordingly, we conclude that the Department established, by clear and convincing evidence, that appellant committed the predicate act enumerated in section 161.001(1)(D) and that termination is in the child’s best interest.

Section 161.001(1)(D) permits termination when a parent knowingly places or keeps a child in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of A.B. and K.B. · filed 2015-08-13(1)(D)

The trial court could reasonably have formed a firm belief or conviction that appellant knowingly placed or knowingly allowed the children to remain in conditions or surroundings which endangered their physical or emotional well-being.

Section 161.001(1)(D) permits termination when a parent knowingly allows a child to remain in surroundings that endanger the child’s physical or emotional well-being; the danger is assessed before the child’s removal.

in the Interest of L.E.S., a Child · filed 2015-08-18(1)(D)

In evaluating termination under ground (D), however, we are to examine the time prior to L.E.S.’ removal to determine whether the environment of the home posed a danger to her physical or emotional well-being.

Section 161.001(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of N.T., a Child · filed 2015-09-02(1)(D)

On this record, we conclude the evidence is both legally and factually sufficient to support a finding by clear and convincing evidence that Mother knowingly placed or knowingly allowed the children to remain in conditions or surroundings which endanger the physical or emotional well-being of the children.

Section 161.001(b)(1)(D) requires clear and convincing evidence that, before removal, a parent knowingly placed or allowed a child to remain in endangering conditions or surroundings.

in the Interest of M.H., II, a Child · filed 2016-02-05(b)(1)(D)

According due deference to the fact- finder’s findings, for the reasons set out below, we nevertheless hold that a rational trier of fact could not have found that the evidence, when viewed in a neutral light, was clear and convincing that Mother knowingly placed or knowingly allowed M.H. to remain in conditions or surroundings that endangered the emotional or physical well-being of M.H.

Section 161.001(1)(D) allows termination when a parent knowingly leaves children in surroundings that endanger their well-being, including continued exposure to an abusive parent.

D. N. and E. M. v. Texas Department of Family and Protective Services · filed 2016-04-08(1)(D)

From this evidence of Mother’s persistent denial of Father’s abuse and her ongoing relationship with Father, we determine that the trial court could have reasonably formed a firm belief that Mother allowed the children to remain in a situation that endangered their well-being and would continue to do so.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

In the INTEREST OF P.R.W., a Child · filed 2016-05-17(b)(1)(D)

Based on all of the foregoing, we conclude that the evidence is legally sufficient because a reasonable trier of fact could form a firm belief or conviction that Mother placed Child in dangerous conditions' or surroundings.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in surroundings that endanger the child's well-being, including by leaving a sick young child alone.

in the Interest of Z.W., a Child · filed 2016-07-13(b)(1)(D)

We find that Cristina's conduct in leaving five-year-old Z.W. at home alone while he was sick, which she judicially admitted endangered Z.W., renders the evidence legally and factually sufficient to show that on the date of Z.W.'s removal from Cristina, Cristina knowingly allowed Z.W. to remain in surroundings which endangered his well-being.

Leaving an infant alone amid risks of falling and suffocation can establish the endangering surroundings ground for termination.

A. R. and C. W. v. Texas Department of Family and Protective Services · filed 2016-10-04(1)(D)

Leaving an infant alone can constitute endangerment under the Family Code. ... Therefore, we conclude that the evidence is legally and factually sufficient to support the termination of Mother’s and Father’s parental rights under subsection (D).

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of D.H. · filed 2016-08-25(b)(1)(D)

We conclude that CPS established, by clear and convincing evidence, that L.P. committed the predicate act enumerated in section 161.001(b)(1)(D) and that termination of L.P.’s parental rights is in D.H.’s best interest.

Section 161.001(b)(1)(D) permits termination when a parent exposes children to unsanitary home conditions that endanger their well-being.

in the Interest of J.R., S.R., C.R., and C.R., Children · filed 2016-08-31(b)(1)(D)

Based on the evidence mentioned above, we conclude the evidence is sufficient to support a firm conviction or belief that Cathy exposed the children to unsanitary conditions in their home which endangered the children’s well-being.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of M.T.C. and J.R.T.C. · filed 2017-02-15(b)(1)(D)

Based upon this evidence, both direct and circumstantial, it was reasonable for the trial court to find that M.C. knowingly placed the children in an endangering environment or that he knowingly allowed the children to remain ... in an endangering environment through his own misconduct coupled with his knowledge of the mother’s drug use.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or leaves a child in surroundings that endanger the child’s physical or emotional well-being.

in the Interest of L. M. M. a Child v. Department of Family and Protective Services · filed 2017-05-11(b)(1)(D)

Considering all the evidence, including Mother’s insistence that she was not aware of about any of L.M.M.’s injuries, there is sufficient evidence to produce a firm belief or conviction in the trial court’s mind that Mother “knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endanger the physical or emotional well-being” of L.M.M. under section 161(b)(1)(D).

Section 161.001(b)(1)(D) permits termination when a parent knows of a potential danger in the child’s surroundings and disregards that risk, even without certain knowledge of an injury.

In re L. M. M. · filed 2017-05-11(b)(1)(D)

Although the parent need not have certain knowledge that an actual injury is occurring, under subsection D, the parent must at least be aware of the potential for danger to the child in such an environment and must have disregarded that risk.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of A. L., a Child · filed 2017-07-31(b)(1)(D)

We conclude that the evidence is factually sufficient to support the trial court’s finding that H.L. knowingly allowed A.L. to remain in conditions or surroundings which endanger her physical well-being.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in endangering conditions or surroundings; prenatal and continued drug use can support that finding.

in the Interest of Z. J. R., a Child · filed 2017-11-16(b)(1)(D)

Viewing the evidence in the light most favorable to an affirmative finding under Section 161.001(b)(1)(D), we conclude that there was sufficiently clear and convincing evidence presented allowing a reasonable fact-finder to form a firm belief or conviction that C.R. knowingly placed or knowingly allowed Z.J.R. to remain in conditions or surroundings which endangered Z.J.R.’s physical or emotional well-being.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or leaves a child in conditions that endanger the child’s physical or emotional well-being; actual injury is unnecessary.

in the Interest of E.M., E.M., J.L., A.L., and M.L., Children · filed 2017-11-21(b)(1)(D)

Based on the evidence presented, a fact-finder could have concluded that the environment of Jeffrey’s and the Telards’ homes created a potential for danger to the children’s physical and emotional well-being that Lester was aware of, but disregarded. Accordingly, we find the evidence both legally and factually sufficient to support the trial court’s finding under Ground D.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in conditions that endanger the child’s physical or emotional well-being.

in the Interest of J.H., A.H., J.H., L.H., and H.H., Children · filed 2017-12-11(b)(1)(D)

Consequently, we conclude that the evidence was legally and factually sufficient to support the subsection (D) endangerment finding.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of A.L.R.M. and W.N.P.M., Children · filed 2018-02-02(b)(1)(D)

Considering the evidence in the light most favorable to the findings, we find that the jury could have reasonably formed a firm belief or conviction that, prior to the children’s removal, Ann knowingly placed the children, or allowed them to remain, in a home environment that posed a danger to their physical and emotional well-being.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in an environment that endangers the child’s physical or emotional well-being, if termination is also in the child’s best interest.

in the Interest of J.N.S. and S.A.L.T., Children · filed 2018-01-04(b)(1)(D)

Because only one ground for termination is necessary, and because the evidence sufficiently supports the trial court’s finding of grounds under section 161.001(b)(1)(D), we need not consider Mother’s second, third, or fourth issue, which challenge the trial court’s other predicate findings.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in surroundings that endanger the child’s physical or emotional well-being.

in the Interest of S.Z., a Child · filed 2018-06-27(b)(1)(D)

We therefore conclude the evidence is legally ... and factually sufficient to support termination of Raymond Z’s parental rights on section 161.001(b)(1)(D) grounds.

Section 161.001(b)(1)(D) permits termination when a parent knowingly leaves a child in surroundings that endanger the child's physical or emotional well-being, including an environment made dangerous by a resident's violence.

in the Interest of K.M., a Child · filed 2018-07-05(b)(1)(D)

Applying the standards articulated above, we conclude that legally and factually sufficient evidence supports the jury’s finding under section 161.001(b)(1)(D) that Mother endangered Kevin.

A parent’s awareness of potential danger is sufficient to establish that the parent knowingly allowed a child to remain in endangering surroundings.

in the Interest of T.S.C., a Child · filed 2019-03-06(b)(1)(D)

Even if Jose did not know for certain that T.S.C. was in a dangerous environment, his awareness of potential endangerment is sufficient.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions that endanger the child’s physical or emotional well-being.

in the Interest of K.S.O.B. A/K/A K.B., N.A.K.B. A/K/A N.B., M.C.P.B. A/K/A M.B., and N.N.I.B. A/K/A N.B., Children v. D · filed 2019-03-19(b)(1)(D)

Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that mother knowingly placed, or knowingly allowed the children to remain, in conditions or surroundings which endangered their physical and emotional well-being.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in surroundings that endanger the child’s physical or emotional well-being.

in the Interest of O. E. R. and L. F. J., Children · filed 2019-03-29(b)(1)(D)

Further, in view of the entire record, we conclude that the disputed evidence is not so significant as to prevent the trial court from forming a firm belief or conviction that termination was justified under Section 161.001(b)(1)(D).

Subsection (b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in an environment that endangers the child’s physical or emotional well-being.

J. K. v. Texas Department of Family and Protective Services · filed 2019-04-17(b)(1)(D)

Viewing all the evidence in the light most favorable to the finding, the district court could have reasonably formed a firm belief or conclusion that J.K. knowingly placed or knowingly allowed the children to remain in a dangerous environment.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in an environment that endangers the child’s physical or emotional well-being.

in the Interest of P.N.T., a Child v. Texas Department of Family and Protective Services · filed 2019-06-11(b)(1)(D)

Considering all the evidence in the light most favorable to the finding, we conclude the trial court could have formed a firm conviction or belief that Mother endangered Paige under subsection D.

Section 161.001(b)(1)(D) provides a ground for termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions or surroundings that endangered the child’s physical or emotional well-being.

in the Interest of E.C.S., A.M.B., T.J.B., and K.S., Children · filed 2019-06-25(b)(1)(D)

The evidence is legally and factually sufficient to support the trial court’s finding of endangerment as to Mother under section 161.001(b)(1)(D).

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of D.S.D.D. · filed 2019-07-11(b)(1)(D)

The evidence was legally and factually sufficient to show that Mother “knowingly placed or knowingly allowed” Daniel to remain in an environment that would endanger his “physical or emotional well-being.” See Tex. Fam. Code. Ann. § 161.001(b)(1)(D). Therefore, we hold that there was clear and convincing evidence to terminate her parent-child relationship under 161.001(b)(1)(D).

A parent’s awareness of a potentially endangering environment is sufficient under subsection (b)(1)(D); certain knowledge of danger is unnecessary.

in the Interest of A.M and H.M., Children · filed 2019-07-25(b)(1)(D)

A parent need not know for certain that the child is in an endangering environment: awareness of such a potential is sufficient.

Section 161.001(b)(1)(D) requires evidence that the child’s living conditions posed a real threat of injury or harm.

in the Interest of I. D. G. v. A. G., E. R. G. and R. J. G., Children · filed 2019-07-30(b)(1)(D)

There is no evidence that the children’s living conditions posed a real threat of injury or harm to them. While the evidence supports termination of Wanda’s parental rights on other grounds, we conclude that the evidence is legally insufficient for a reasonable trier of fact to form a firm belief or conviction that Wanda knowingly placed or knowingly allowed the children to remain in conditions or surroundings which endangered their physical or emotional well-being.

Subsection (b)(1)(D) is satisfied when a parent knowingly lets a child remain in surroundings that endanger the child’s physical or emotional well-being.

in the Interest of B. M. S. and P. L. S., Children · filed 2019-08-07(b)(1)(D)

Accordingly, we hold that the evidence was legally and factually sufficient to support the subsection D endangerment finding.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of E. A. R., a Child · filed 2019-08-21(b)(1)(D)

We conclude that the evidence, viewed in the light most favorable to the challenged finding, was sufficient for a reasonable factfinder to have formed a firm belief or conviction that Mary knowingly allowed Eddie to remain in conditions or surroundings which endangered his physical well-being.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions that endanger the child’s physical or emotional well-being.

in the Interest of F.R. AKA F.R. AKA F.R., A.L.R., I.R.L. AKA I.R.L., Children · filed 2019-11-04(b)(1)(D)

Leaving the small children alone on June 23, 2017, in a filthy home, leaving them with access to the stove and an unprotected electrical outlet, leaving them unwashed and unfed before removal and during visits, leaving them without medical attention when sick and suffering from extremely high fevers on another occasion, and engaging in threatening and assaultive conduct when others decided to help the children may reasonably be construed by a fact-finder as clear and convincing evidence that the environment of the children at bar posed a danger to their physical and emotional health.

Subsection (b)(1)(D) permits termination when a parent knowingly allows a child to remain in endangering conditions; awareness of potential harm is sufficient.

in the Interest of A.D.G., a Child · filed 2019-12-04(b)(1)(D)

The Department did not have to prove that Mom knew for certain that A.D.G. would be harmed, it just needed to prove that Mom was aware of the potential for harm and allowed A.D.G. to remain in an endangering environment.

A parent’s failure to protect a child from endangering conditions can support termination under subsection (D).

in the Interest of L.J.G., S.A.M., and A.C.F. · filed 2019-11-18(b)(1)(D)

B.G.’s failure to act to protect L.J.G. was sufficient evidence to support termination under subsection (D).

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows children to remain in a home where violence endangers them.

in the Interest of J.L., Jr., a Child · filed 2019-12-09(b)(1)(D)

Moreover, although Mother had received services over the years to address the Department’s concerns and Father had been prohibited from having any communication or contact with her, she maintained a relationship with him and continued to expose the children to violence in the home. From this evidence, a reasonable factfinder could have formed a firm belief or conviction that Mother had knowingly placed and allowed the children to remain in an endangering environment.

Subsection (D) requires clear and convincing evidence of the child’s endangering surroundings or conditions, while subsection (E) requires a continuing course of endangering conduct.

in the Interest of C.V.L., a Child · filed 2019-12-13(b)(1)(D) and (E)

The party seeking termination must still present clear and convincing evidence of the child’s actual physical surroundings or conditions that were created by the endangering conduct to satisfy the requirements of subsection (D) and must show a continuing course of conduct to satisfy the requirements of subsection (E).

Section 161.001(b)(1)(D) permits termination based on a parent’s earlier placement of children in endangering conditions, even if the parent was incarcerated when they were later removed.

in the Interest of K.C. and K.C., Children · filed 2019-12-31(b)(1)(D)

However, the record reflects that, prior to her incarceration, Appellant had placed the children in conditions or surroundings that endangered their physical or emotional well-being. As aptly stated by the older child, this is the first home that she has had in which she did not have to “worry about people coming into her room at night to potentially harm her.” We hold that the evidence is legally and factually sufficient to uphold the trial court’s finding under subsection (D).

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in conditions that endanger the child’s physical or emotional well-being.

in the Interest of S.L.L., a Child · filed 2020-01-09(b)(1)(D)

Accordingly, we conclude that the evidence was legally and factually sufficient to support termination under subsection (D).

Subsection (b)(1)(D) permits termination when a child’s environment endangers the child’s physical or emotional health, even if the parent’s conduct consists of a single act or omission.

in the Interest of Z.A.M.-L., a Child · filed 2020-01-13(b)(1)(D)

Section 161.001(b)(1)(D) requires a showing that the environment in which the child was placed posed a danger to the child’s physical or emotional health. It also permits termination based on a single act or omission by the parent.

Section 161.001(b)(1)(D) requires clear and convincing evidence that a parent knowingly allowed a child to remain in an endangering environment; the mother’s failure to take epilepsy medication did not establish that ground without evidence of the resulting danger to her children.

in the Interest of V.A. · filed 2020-01-17(b)(1)(D)

We conclude the evidence is legally insufficient to support the trial court’s finding that Mother engaged in the conduct described in Family Code section 161.001(b)(1)(D).

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows children to remain in an abusive home that endangers their physical or emotional well-being, even if the other parent is the abuser.

v. P. A/K/A M. Y. v. Texas Department of Family and Protective Services · filed 2020-02-04(b)(1)(D)

What Mother does not explain, however, is why a jury could not have reasonably believed that she failed to promptly remove the children from a dangerous environment—even if, as she contends, A.Y. was the lone abuser and solely responsible for creating that violent environment.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in an endangering environment; a parent’s criminal conduct and resulting instability can support that finding.

in the Interest of A.S. and A.M.,Children · filed 2020-03-02(b)(1)(D)

We conclude that the evidence of Father’s voluntary criminal behavior before and after Mary’s birth, viewed in the appropriate deferential light, revealed that Father’s voluntary criminal actions subjected Mary to a life of uncertainty and instability and allowed an inference that similar conduct would recur if Mary were returned to Father; thus, legally and factually sufficient evidence supported the trial court’s finding that Father violated Section 161.001(b)(1)(D).

Section 161.001(b)(1)(D) covers endangering conditions or surroundings outside a child’s home.

in the Interest of A.R.G. and J.D.M.G., Children · filed 2020-03-18(b)(1)(D)

Subsection (D) concerns endangering “conditions or surroundings” generally and is not limited to a child’s home.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of C.W. Children · filed 2020-04-29(b)(1)(D)

Therefore, in considering the entire record, we conclude the evidence is legally and factually sufficient to support the trial court’s finding that Ana “knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endanger the physical or emotional well-being of the child.” TEX. FAM. CODE ANN. § 161.001(b)(1)(D); see also In re C.J.G., 2019 WL 5580253, at *2 (stating that a “child is endangered when the environment creates a potential for danger that the parent is aware of but consciously disregards”).

Section 161.001(b)(1)(D) permits termination when a parent knowingly leaves children in surroundings endangered by domestic violence.

in the Interest of L.W. and K.R., Children · filed 2020-08-13(b)(1)(D)

The violence in the home and Mother’s failure to remove herself and her children from her relationship with Father created a clear potential danger to the children that Mother disregarded.

Subsection (b)(1)(D) requires evidence that the parent knew of the child’s endangering conditions or surroundings.

in the Interest of N.N.M., a Child · filed 2020-08-19(b)(1)(D)

However, there is no evidence that he had any knowledge or awareness of the conditions in which N.N.M.’s was living until he was contacted by the Department, well after the time of removal. See In re N.F., 2020 WL 2070286, at *21 (explaining that subsection (D) cannot be basis for termination if the parent was unaware of the endangering environment). Therefore, we hold the evidence is legally insufficient to support the finding under subsection (D).

Subsection (b)(1)(D) requires clear and convincing evidence that a parent knowingly placed or allowed a child to remain in an endangering environment.

in the Interest of A.P., H.L., B.L., and G.Y., Children · filed 2020-11-19(b)(1)(D)

We conclude the evidence is legally insufficient for a reasonable trier of fact to form a firm belief or conviction that Father knowingly placed or knowingly allowed the children to remain in conditions or surroundings which endangered their physical or emotional well-being.

Subsection (b)(1)(D) is satisfied when clear and convincing evidence shows a parent knowingly placed a child in surroundings that endangered the child.

C. C. v. Texas Department of Family and Protective Services · filed 2020-11-20(b)(1)(D)

Applying the appropriate standards of review, we conclude that the district court could have reasonably found by clear and convincing evidence that Mother knowingly placed Alice in conditions or surroundings that endangered her.

Unsanitary home conditions can support termination when a parent knowingly allows children to remain in surroundings that endanger their physical or emotional well-being.

D. J. and C. C. v. Texas Department of Family and Protective Services · filed 2020-12-17(b)(1)(D)

After considering all the evidence in the light most favorable to the findings, along with any undisputed evidence contrary to the finding, we conclude that a reasonable factfinder could have formed a firm belief or conviction that Father knowingly placed or knowingly allowed the children to remain in conditions or surroundings which endangered their physical or emotional well-being.

Section 161.001(b)(1)(D) concerns whether the child’s environment was endangering when the child was removed; inadequate help obtaining later services does not affect that inquiry.

T. A. W. and C. E. v. Texas Department of Family and Protective Services · filed 2021-01-08(b)(1)(D)

Assuming the accuracy of Mother’s claim that the Department’s help with obtaining services was inadequate, that has no bearing on whether the children were in an environment that endangered them when they were removed.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or keeps a child in conditions that endanger the child’s physical or emotional well-being.

in the Interest of X.J.R., A.W.R., Z.N.B., L.K.B., and G.E.B. v. . · filed 2021-01-13(b)(1)(D)

Considering all the evidence under the appropriate standards of review, we conclude the trial court could have formed a firm belief or conviction that Dad’s course of conduct met statutory ground (D). See TEX. FAM. CODE ANN. § 161.001(b)(1)(D). Dad reportedly punched X.J.R. in the stomach, spanked X.J.R. and A.W.R. with a belt, hit them in the face and choked them, and he was abusive toward Mom.

Subsection (b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions that endanger the child’s physical or emotional well-being.

in the Interest of S. v. and J. K. N. AKA K. v. Children · filed 2021-01-21(b)(1)(D)

Viewing the evidence in the light most favorable to the trial court’s findings, we conclude that the trial court could have formed a firm belief or conviction that Mother knowingly placed, or knowingly allowed the children to remain, in conditions or surroundings which endangered their physical and emotional well-being.

Subsection (b)(1)(D) permits termination when a parent knowingly allows a child to remain in an environment that endangers the child’s physical or emotional well-being.

in the Interest of C.W.M.P., Jr. A/K/A C.P., a Child v. Texas Department of Family and Protective Services · filed 2021-01-26(b)(1)(D)

Beginning with subsection (D), evidence of Charlie’s environment before he left Mother’s care shows Mother knowingly allowed Charlie to remain in conditions that endangered his physical or emotional well-being.

Section 161.001(b)(1)(D) permits termination when a parent’s drug use during pregnancy places a child in conditions that endanger the child’s physical well-being.

in the Interest of A.J.F., a Child · filed 2021-02-04(b)(1)(D)

We hold this evidence to be legally and factually sufficient to support the finding that S.G. knowingly placed A.J.F. in conditions or surroundings that endangered the child’s physical well-being.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions that endanger the child’s physical or emotional well-being.

in the Interest of A.C., K. L.C. III and L. C. v. Department of Family and Protective Services · filed 2021-03-04(b)(1)(D)

The Department responds that substantial evidence exists in the record to support the subsection (D) predicate ground. We agree with the Department.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of C.L.R., a Child · filed 2021-03-24(b)(1)(D)

Looking at the evidence in the light most favorable to the finding of the trial court, we conclude that a reasonable factfinder could have formed a firm conviction that Olivia knowingly placed or allowed her child to remain in conditions or surroundings that endangered his physical or emotional well-being.

Subsection (b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of J.I., a Child · filed 2021-04-14(b)(1)(D)

Based on the foregoing evidence, we conclude that the evidence was sufficiently clear and convincing the support the trial court’s findings under subsection (b)(1)(D) as to both Betty and Pete.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places a child in surroundings that pose a potential for injury, even if the dangerous conduct occurs outside the child’s presence.

in the Interest of A.M.M., a Child · filed 2021-04-14(b)(1)(D)

However, subsection (D) does not require Father’s drug use to have occurred in A.M.M.’s presence; the ground is established if A.M.M. was exposed to the potential for injury as a result of Mother’s knowing actions or omissions.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions or surroundings that endanger the child’s well-being.

J. T. v. Texas Department of Family and Protective Services · filed 2021-06-30(b)(1)(D)

The evidence in this record thus supports the trial court’s finding that Father knowingly placed or allowed S.T. to remain in conditions or surroundings that endangered her well-being.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of D.R. and C.R., Children · filed 2021-08-05(b)(1)(D)

We find that legally and factually sufficient evidence, including Mother’s drug use and the home’s exposed wires and boards, established by clear and convincing evidence that Mother placed or knowingly allowed the children to remain in conditions or surroundings that endangered their physical well-being.

Subsection (b)(1)(D) permits termination when clear and convincing evidence shows a parent knowingly allowed children to remain in conditions that endangered their physical or emotional well-being.

in the Interest of J.S., G.S., and I.F., Children · filed 2021-09-17(b)(1)(D)

Based on the above and foregoing, we find evidence in the record shows there is legally and factually sufficient evidence supporting the termination of S.F.’s parental rights to her three children pursuant to Family Code subsection 161.001(b)(1)(D).

Subsections (b)(1)(D) and (E) permit termination when parents expose children to unsanitary living conditions that endanger their well-being, without requiring proof of actual injury.

R. P. and M. J. v. Texas Department of Family and Protective Services · filed 2021-10-13(b)(1)(D), (E)

Viewing the evidence under the applicable standards of review, we conclude that the evidence was legally and factually sufficient to support the trial court’s findings under subsections (D) and (E).

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or leaves a child in surroundings that endanger the child’s physical or emotional well-being; awareness of potential danger is sufficient.

in the Interest of A. J. A. A/K/A Unknown Female A/K/A A. A., a Child v. Department of Family and Protective Services · filed 2021-12-02(b)(1)(D)

It was not necessary, however, for Father to know for certain the danger to which Annie would be exposed. Only evidence demonstrating Father was aware of the potential for danger is necessary.

Subsection (b)(1)(D) requires clear and convincing evidence that a parent knowingly placed or allowed a child to remain in conditions that endangered the child’s physical or emotional well-being.

in the Interest of I.R.M., A.M.M., V.M., Children · filed 2021-12-22(b)(1)(D)

We conclude that the Department’s evidence, even when viewed in the light most favorable to the judgment, would not allow a reasonable factfinder to form a firm belief or conviction that M.M. knowingly placed or knowingly allowed the children to remain in conditions that endangered their physical or emotional well-being.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions or surroundings that endanger the child’s well-being.

T. D. v. Texas Department of Family and Protective Services · filed 2022-01-06(b)(1)(D)

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 Mother knowingly ... placed or allowed Sam and Leon to remain in conditions or surroundings that endangered their well-being.

Section 161.001(b)(1)(D) permits termination when a parent knowingly creates or allows an environment that endangers a child’s physical or emotional well-being.

in the Interest of R.C. and K.C., Children · filed 2022-01-18(b)(1)(D)

Based on the evidence presented, a reasonable fact-finder could have concluded that the environment created by Father’s conduct, including his drug use, created a potential for danger to R.C.’s and K.C.’s physical and emotional well-being that Father was aware of but disregarded. Accordingly, we find the evidence both legally and factually sufficient to support the trial court’s finding under Ground D.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in surroundings that endanger the child’s physical or emotional well-being.

in the Interest of J.K.N.G. and A.K.A.F.M., Children · filed 2022-03-09(b)(1)(D)

On this record, we hold the trial court could have reasonably formed a firm belief or conviction that Jenna knowingly placed or allowed her children to remain in conditions or surroundings that endangered their physical or mental well-being.

Section 161.001(b)(1)(D) requires proof that a parent knowingly placed or allowed the child to remain in an endangering environment; it does not support termination when the child was never in the parent’s home or care.

in the Interest of L.E.R., a Child · filed 2022-04-12(b)(1)(D)

Lori was never in Mother’s home or care; Lori never lived with Mother. Therefore, Mother never placed or allowed Lori to remain in conditions or surroundings which endangered Lori’s physical or emotional well-being as required by subsection D. We conclude the evidence is legally insufficient to support the trial court’s finding that Mother engaged in the conduct described in Family Code section 161.001(b)(1)(D).

Subsection (b)(1)(D) requires clear and convincing evidence that a parent knowingly placed or allowed a child to remain in an endangering environment; a parent’s imperfect response to the other parent’s addiction does not alone establish that ground.

in the Interest of J.W., a Child · filed 2022-05-27(b)(1)(D)

On this record, the jurors may have reasonably concluded that Father could have better handled the difficult situation into which he was thrust by Mother’s addiction, but they could not have reasonably concluded by clear and convincing evidence that Father disregarded his parental obligations to the degree that he knowingly “allowed” J.W. to be placed or remain in a dangerous environment.

Section 161.001(b)(1)(D) permits termination when a parent’s illegal drug use during pregnancy exposes a child in utero to conditions that endanger the child’s physical well-being.

in the Interest of A.M.A., a Child · filed 2022-04-14(b)(1)(D)

The evidence shows that C.G. knowingly used illegal drugs throughout her pregnancy. At birth, A.M.A. tested positive for the presence of illegal drugs, supporting an inference that C.G.’s drug use created conditions or surroundings that exposed A.M.A. to the substances in utero. We hold this evidence to be legally and factually sufficient to support the finding that C.G. knowingly placed A.M.A. in conditions or surroundings that endangered the child’s physical well-being.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places a child in surroundings that endanger the child’s physical or emotional well-being.

in the Interest of G. M., a Child · filed 2022-06-21(b)(1)(D)

Based on the foregoing, the trial court could have reasonably formed a firm conviction that Mother knowingly placed G.M. in conditions or surroundings which endangered G.M.’s physical or emotional well-being.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in surroundings that endanger the child’s physical or emotional wellbeing.

A.N.W.S. v. Texas Department of Family and Protective Services · filed 2022-07-07(b)(1)(D)

This evidence of Mother’s actions, including exposing Children to illegal substances and the possibility of being left alone, considered along with the inability to assess Children’s living conditions while incarcerated, supports the finding that Mother knowingly placed or knowingly allowed Children to remain in conditions or surroundings which endangered their physical or emotional wellbeing. Considered in the light most favorable to the trial court’s finding, the evidence is legally sufficient to support the trial court’s determination that termination of Mother’s parental rights was justified under section 161.001(b)(1)(D).

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows children to remain in surroundings that endanger their physical or emotional well-being.

in the Interest of G. J. A. and H. L. A., Children · filed 2022-08-04(b)(1)(D)

We conclude there is clear and convincing evidence that Mother knowingly placed or knowingly allowed G.J.A. and H.L.A. to remain in conditions or surroundings which endangered the physical and emotional well being of the children.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions that endanger the child’s physical or emotional well-being.

in the Interest of C.S. and A.S., Children · filed 2022-08-16(b)(1)(D)

Under this record, we find that the trial court reasonably could have formed a firm belief or conviction that Father knowingly placed or knowingly allowed C.S. and A.S to remain in conditions or surroundings that endangered their physical or emotional well-being. Therefore, we find that legally and factually sufficient evidence supports the trial court’s finding terminating Father’s parental rights under statutory ground D.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed children in surroundings that endangered their physical or emotional well-being.

Interest of C.H., J.H., E.H., I.B.H., and I.A.H. · filed 2022-08-31(b)(1)(D)

We hold the trial court reasonably could have formed a firm belief or conviction that, before removal, Mother placed the children in surroundings which endangered their physical and emotional well-being.

Section 161.001(b)(1)(D) permits termination when a parent knowingly leaves a child in conditions that endanger the child’s physical or emotional well-being; medical neglect can support that finding.

in the Interest of J.A.R.R., J.N.R., and M.A.R., Children · filed 2022-09-21(b)(1)(D)

Based on this evidence, a reasonable trier of fact could have found that the children’s pre-removal environment was a source of endangerment to their physical or emotional well-being.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed a child in conditions that endangered the child’s physical or emotional well-being.

in the Interest of C.C.H., a Child · filed 2022-10-12(b)(1)(D)

From the record of Mother’s acts prior to C.C.H.’s birth, a rational fact-finder could form a firm belief or conviction that Mother knowingly placed C.C.H. in a condition that endangered her physical well-being. Consequently, we conclude that the evidence was both legally and factually sufficient to support termination of Mother’s parental rights under Ground D.

Subsection (b)(1)(D) makes knowingly placing or allowing a child to remain in conditions that endanger the child’s physical or emotional well-being a ground for termination.

J. M. and R. A. G. v. Texas Department of Family and Protective Services · filed 2022-10-13(b)(1)(D)

Viewing the evidence under the applicable standard of review for legal sufficiency, we conclude that the evidence was legally sufficient to support the jury’s finding under subsection (D).

Drug use and other unsafe conditions in a child’s home can support an endangerment finding under subsection (b)(1)(D).

in the Interest of B.C. and Z.C., Children · filed 2022-11-23(b)(1)(D)

Thus, even if the trial court had not required Father to answer the question about Mother’s drug use, there would have been ample evidence to support the trial court’s Section (D) and best interest findings.

A parent who knows a child’s caregiver uses methamphetamines may satisfy subsection (D) by allowing the child to remain in that environment.

E. G. v. Texas Department of Family and Protective Services · filed 2022-12-28(b)(1)(D)

We conclude that this evidence is legally and factually sufficient to support the district court’s finding that Father knowingly placed or knowingly allowed Daughter to remain in conditions or surroundings which endangered Daughter’s physical or emotional well-being of the child.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

in the Interest of P.W. and E.W., Children · filed 2023-01-04(b)(1)(D)

Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s conclusion that Holly’s parental rights to P.W. should be terminated under section 161.001(b)(1)(D) of the Texas Family Code.

Subsection (D) permits termination when a parent knowingly allows a child to remain in unsanitary conditions that endanger the child.

M. L. and S. D. v. Texas Department of Family and Protective Services · filed 2023-02-16(b)(1)(D)

She did not dispute that the removal was ... appropriate because of the home’s condition and knew that it was unsafe for Child because of how dirty it was. And Kaila added that the home was in fact in “horrible” condition. We conclude under the applicable standard that the evidence was legally sufficient to support the Subsection (D) finding against Mother.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in conditions that endanger the child’s physical or emotional well-being.

In the Interest of J.H. A/K/A I. J. C.-H. A/K/A J. I. C. H. a Child v. Department of Family and Protective Services · filed 2023-02-23(b)(1)(D)

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 mother knowingly placed, or knowingly allowed J.H. to remain, in conditions or surroundings which endangered his physical or emotional well-being.

Section 161.001(b)(1)(D) makes a parent’s knowing placement of a child in endangering conditions or surroundings a ground for termination.

J. B. M. H. and Y. C. B. v. Texas Department of Family and Protective Services · filed 2023-04-13(b)(1)(D)

We conclude that the evidence is legally and factually sufficient to support a finding that Father and Mother knowingly placed the children in conditions or surroundings which endangered their physical or emotional well-being so as to support a finding of endangerment under Subsection (D).

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows a parent knowingly exposed a child to dangerous conditions before removal.

In the Interest of J.M.R., a Child v. the State of Texas · filed 2023-05-03(b)(1)(D)

We conclude the evidence of Mom’s course of conduct was legally and factually sufficient for the trial court to have found by clear and convincing evidence that, before J.M.R. was removed, Mom knowingly exposed her to dangerous conditions.

Subsection (b)(1)(D) permits termination when a parent knowingly exposes a child to endangering conditions or surroundings; a single act or omission may suffice.

In the Interest of D.D.D., Children v. Department of Family and Protective Services · filed 2023-08-01(b)(1)(D)

A finding under subsection (D) may be based on a single act or omission. ... The evidence in the record demonstrates that Mother allowed David to be in an environment in which he could—and did—ingest a dangerous drug.

Section 161.001(b)(1)(D) permits termination when legally and factually sufficient evidence shows that a child’s conditions or surroundings endangered the child’s physical or emotional well-being.

N. M. and C. M. v. Texas Department of Family and Protective Services · filed 2023-11-01(b)(1)(D)

Based on our review of the record, we conclude that legally and factually sufficient evidence supports the jury’s Subsection (D) endangerment finding and, because only one statutory-predicate ground need be established, see A.V., 113 S.W.3d at 361, we dispense with a lengthy explanation of our decision and also with addressing Father’s challenges to the (E) and (O) grounds, see Tex. R. App. P. 47.1, 47.4.

Section 161.001(b)(1)(D) permits termination when a parent knowingly exposes children to an endangering environment, including one the parent creates through physical and sexual abuse.

In the Interest of E.W., Jr., S.W., A.W., M.W., and A.W., Children v. the State of Texas · filed 2023-11-03(b)(1)(D)

In this case, Father was not only aware of the potential for danger to the children, he produced the endangering environment by his actions. Based on this record, we find that the evidence was legally and factually sufficient to support the trial court’s finding under statutory ground D.

Section 161.001(b)(1)(D) permits termination on clear and convincing evidence that a parent knowingly exposed a child to conditions endangering the child’s physical or emotional well-being; drug abuse during pregnancy can satisfy that ground.

In the Interest of J.W., a Child v. the State of Texas · filed 2023-11-08(b)(1)(D)

The latter permits termination upon clear and convincing proof that a parent has “knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endanger the physical or emotional well-being of the child[.]” TEX. FAM. CODE ANN. § 161.001(b)(1)(D). ... Thus, the trial court’s finding of (D) had the support of both legally and factually sufficient evidence.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions that endangered the child’s physical or emotional well-being.

In the Interest of S.N.R-T., A/K/A S.R-T., S.J.R-T., A/K/A S.T., D.G.R-T., A/K/A D.T., A.G.R-T., A/K/A A.T., E.U.T.M., A · filed 2023-11-14(b)(1)(D)

Therefore, we conclude the evidence is factually sufficient to support termination under subsection (D).

Section 161.001(b)(1)(D) allows termination when a parent knowingly exposes a child to an endangering environment, including by repeatedly leaving young children without supervision.

In the Interest of E.J. a Child v. Texas Department of Family and Protective Services · filed 2023-11-21(b)(1)(D)

The trial court reasonably could have concluded that Mother’s pattern of leaving her young children home alone without supervision contributed to an environment that endangered Emma’s, Bella’s, and Brianna’s physical and emotional well-being.

Section 161.001(b)(1)(D) supports an endangerment finding when parents knowingly allow children to remain in surroundings that threaten their physical or emotional well-being.

In the Interest of H.S., B.S., and M.S., Children v. the State of Texas · filed 2024-03-21(b)(1)(D)

Applying the applicable standards of review, we conclude that the evidence here is legally and factually sufficient for the jury to have formed a firm belief or conviction that Mother and Father had knowingly placed or knowingly allowed all three children to remain in conditions or surroundings that endangered their physical or emotional well-being.

Subsection (b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed a child to remain in conditions or surroundings that endangered the child’s physical or emotional well-being.

In the Interest of D.M. and D.M v. the State of Texas · filed 2024-01-25(b)(1)(D)

Viewing the evidence in the light most favorable to the jury’s findings, we conclude that the jury could reasonably have formed a firm belief or conviction that Cherie, through her acts or omissions, knowingly placed or knowingly allowed Drew and Dennis to remain in conditions or surroundings that endangered their physical or emotional well-being.

Subsection (b)(1)(D) requires evidence connecting the parent’s conduct to an endangering environment for the child before removal; incarceration alone does not establish that connection.

In the Interest of M.A.H., a Child v. the State of Texas · filed 2024-01-31(b)(1)(D)

While a parent’s incarceration can negatively impact a child’s living environment and well-being sufficient to show endangerment, this evidence is too remote in time and lacks any connection to M.A.H.’s living environment in August of 2022 to support a finding under subsection (D).

A parent’s failure to protect a child from a partner’s abuse can support termination under subsection (D) when it knowingly leaves the child in endangering conditions.

In the Interest of L. R. D. and K. A. M. v. Department of Family and Protective Services · filed 2024-02-13(b)(1)(D)

Thus, the evidence demonstrates that Mother “knowingly placed or knowingly allowed the child[re] to remain in conditions or surroundings which endanger[ed] the physical or emotional well-being of the child[ren]” when she failed to protect Laurel from her partner’s abuse.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to live in conditions that endanger the child, including a home without a working toilet or adequate food.

M. R., C. B. and J. R. v. Texas Department of Family and Protective Services · filed 2024-02-14(b)(1)(D)

Julie and Connor knowingly allowed their children to reside in dangerous conditions with no working toilet, a lack of food, and unsanitary conditions.

Subsection (b)(1)(D) permits termination when a parent knowingly allows a child to remain in conditions that endanger the child’s physical or emotional well-being.

In the Interest of A.C.T.M., a Child v. the State of Texas · filed 2024-02-15(b)(1)(D)

By failing to remove herself and A.C.T.M. from the warehouse where A.C.T.M. was inadequately fed to the point she became severely malnourished and eventually suffered cardiac arrest and became physically immobile, the trial court could have reasonably found that M.M. knowingly allowed A.C.T.M. to remain in conditions or surroundings which endangered A.C.T.M.’s physical or emotional well-being.

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows a parent knowingly placed a child in an environment that endangered the child’s physical or emotional well-being.

In the Interest of Z.E.C. and E.K.M. A/K/A E.C.M., Children v. the State of Texas · filed 2024-02-26(b)(1)(D)

Viewing this evidence in a light most favorable to the trial court’s finding, as we must, we hold the evidence is legally and factually sufficient to support the trial court’s finding that Z.C. knowingly placed Z.E.C. and E.K.M. in an environment that endangered their physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) allow termination when a parent knowingly keeps a child in endangering conditions or engages in endangering conduct; prolonged unsanitary living conditions can support both grounds.

In the Interest of J.W., Jr., a Child v. Department of Family and Protective Services · filed 2024-04-11(b)(1)(D)–(E)

This is legally sufficient evidence of unsanitary conditions to support a finding of child endangerment under (D) or (E).

Section 161.001(b)(1)(D) provides a predicate ground for termination when clear and convincing evidence shows that a parent knowingly allowed a child to remain in conditions endangering the child’s physical or emotional well-being.

In the Interest of H.J.E.Z, B.A.E.Z, J.J.M.E, J.J.E, D.D.E, Children v. Department of Family and Protective Services · filed 2024-04-11(b)(1)(D)

To support a finding under predicate ground (D), the Department had the burden of showing that the Mother “knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endanger the physical or emotional well-being of the child.” See Tex. Fam. Code § 161.001(b)(1)(D). ... Absent such disputed evidence, we conclude that the evidence is legally and factually sufficient to support the trial court’s finding under predicate ground (D).

A parent’s illegal drug use and repeated exposure of children to domestic violence can support an endangering-conditions finding under section 161.001(b)(1)(D).

In the Interest of A.J.A., A.O.B., M.B., Jr., and M.D.B., Children v. the State of Texas · filed 2024-04-17(b)(1)(D)

Accordingly, we hold the evidence is legally and factually sufficient to support the trial court’s finding under section 161.001(b)(1)(D).

Section 161.001(b)(1)(D) permits termination when a parent places or knowingly allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

In the Interest of D.L. and D.L., Children v. the State of Texas · filed 2024-04-25(b)(1)(D)

We find the evidence was legally and factually sufficient to support the trial court’s finding that Mother placed or knowingly allowed the children to remain in conditions or surroundings that endangered the children’s physical or emotional well-being.

Subsection (b)(1)(D) permits termination when a parent knowingly places a child in surroundings that endanger the child’s physical or emotional well-being.

S. A. D. and B. M. P. v. Texas Department of Family and Protective Services · filed 2025-02-21(b)(1)(D)

Based on the evidence in the record, the trial court could have formed a reasonable belief that Father knowingly placed Child in conditions or surroundings which endangered Child’s physical or emotional well-being by leaving Child in Kaitlynn’s care.

Section 161.001(b)(1)(D) permits termination when a parent knowingly exposes a child to endangering conditions, including methamphetamine use throughout pregnancy.

In the Interest of V.M.C.G, a Child v. the State of Texas · filed 2025-03-19(b)(1)(D)

Based on Mother’s admitted methamphetamine use throughout her pregnancy and her positive test for methamphetamine at V.M.C.G.’s birth, the trial court could have formed a firm belief or conviction Mother’s actions endangered V.M.C.G. by knowingly placing her or allowing her to remain in conditions or surroundings endangering her physical or emotional well-being.

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

In the Interest of M.A.M, M.X.M., and M.J.M., Children v. the State of Texas · filed 2025-03-19(b)(1)(D)

After reviewing the evidence under the appropriate standards of review, we conclude that a factfinder could have reasonably formed a firm belief or conviction that Mother knowingly allowed the children to remain in conditions and surroundings that endangered the physical or emotional well-being of the children (e.g., continuing to engage in a relationship with Father despite Father committing domestic violence against her and continuing to reside in a home that is unfit for children).

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions that endanger the child’s physical or emotional well-being.

In the Interest E. A. P. and M. A. P.- R. v. Department of Family and Protective Services · filed 2025-05-22(b)(1)(D)

Regardless of the children’s living conditions before the standoff, the fact that Mother knowingly placed or allowed Eric and Mia to remain in endangering circumstances on December 14, 2022 and afterwards by continuing to live with Mike is sufficient to support termination of Mother’s parental rights to the children under Subsection (D).

Section 161.001(b)(1)(D) permits termination when a child’s unexplained, non-accidental injuries support an inference that the parent knew of and disregarded an endangering environment.

In the Interest of K.P.-A. and K.P.-A., Children v. the State of Texas · filed 2025-05-22(b)(1)(D)

This evidence supports termination under Subsection D.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or leaves a child in conditions or surroundings that endanger the child’s physical or emotional wellbeing.

L. P. v. Texas Department of Family and Protective Services · filed 2025-07-03(b)(1)(D)

Thus, the evidence is legally and factually sufficient to support the trial court’s termination of Mother’s parental rights under Subsection (D).

Section 161.001(b)(1)(D) permits termination when a parent knowingly allows a child to remain in a home where another person physically abuses the child.

In the Interest of B. A. A/K/A B.L.A. a Child v. Department of Family and Protective Services · filed 2025-09-16(b)(1)(D)

Here, there is ample evidence that Thomas, mother’s then-boyfriend, physically abused B.A. in the home, and mother knew, at the very least, that Thomas was hitting B.A. This is sufficient to support termination of mother’s parental rights under Texas Family Code section 161.001(b)(1)(D).

Section 161.001(b)(1)(D) permits termination when a parent’s conduct creates an environment that endangers a child before removal, including through alcohol misuse or exposure to an unsafe person.

In the Interest of S.G., a Child v. the State of Texas · filed 2025-11-19(b)(1)(D)

Under subsection (D), we consider evidence of the child’s environment before the child’s removal. ... We conclude the evidence is legally and factually sufficient to support the trial court’s finding under subsection (D).

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or allows a child to remain in conditions or surroundings that endanger the child’s physical or emotional well-being.

In the Interest of K.N., M.N., and M.N., Children v. the State of Texas · filed 2026-02-19(b)(1)(D)

Thus, the evidence is legally and factually sufficient to support the trial court’s endangerment finding under Subsection (D).

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or keeps a child in endangering conditions; drug use coupled with unstable housing and unemployment can support that finding.

In the Interest of M. H. a Child v. Department of Family and Protective Services · filed 2026-02-19(b)(1)(D)

We therefore hold that the evidence is both legally and factually sufficient to support the trial court’s endangerment finding under subsection (D).

Section 161.001(b)(1)(D) permits termination when clear and convincing evidence shows that a parent knowingly placed or allowed children to remain in conditions that endangered their physical or emotional well-being.

In the Interest of B.M.W and L.LW v. Department of Family and Protective Services · filed 2026-04-07(b)(1)(D)

Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that mother knowingly placed, or knowingly allowed the children to remain, in conditions or surroundings which endangered their physical or emotional well-being. See id.

Section 161.001(b)(1)(D) covers a parent who knowingly leaves a child with a drug user whose care endangers the child’s physical or emotional well-being.

In the Interest of R.G., III, a Child v. the State of Texas · filed 2026-05-21(b)(1)(D)

He knowingly placed or knowingly allowed Ryan to remain in conditions that endangered his physical or emotional well-being by leaving him in the care of Mother—a known drug addict who had a pattern of continued drug use and neglect.

A prior termination under subsection (1)(M) can support termination when evidence shows the parent's criminal and drug problems persist.

Avery v. State · filed 1997-09-16(1)(M)

Based upon this evidence, we hold the trial court could find by clear and convincing evidence that Avery’s problems with crime and drug abuse still existed. The trial court did not err in considering the evidence of the earlier termination. Moreover, because we have determined that the trial court properly terminated Avery’s parental rights under subsection (1)(M) and that Avery does not challenge the trial court’s finding of termination in the best interest of the child, we neéd not address Avery’s constitutional challenges to subsection (1)(D) and (1)(E).

Section 161.001 permits affirmance of a parental-rights termination when all challenged statutory findings have factually sufficient evidence.

Bach v. Texas Department of Protective and Regulatory Services · filed 1999-04-29

Because there is factually sufficient evidence to support all three of the challenged findings that justify terminating appellant's parental rights under section 161.001 of the Family Code, we affirm the trial court's decree terminating appellant's parental rights.

Subsection (1)(L) can independently support termination despite error concerning subsection (1)(D).

Segovia v. Texas Department of Protective & Regulatory Services · filed 1998-10-29(1)(L)

In other words, whatever error the trial court may have committed in basing the termination of the parent-child relationship on section 161.001(1)(D) is rendered harmless because there are other grounds under section 161.001(1)(L) which justify termination of appellant’s parental rights.

Section 161.001(1)(M) allows a prior termination decree based on findings under subsections (D) or (E) to establish that ground for termination without relitigating the earlier conduct.

In Re JMM · filed 2002-06-13(1)(M)

We hold that, when a prior decree of termination as to another child is properly admitted into evidence, the TDPRS need not reestablish that the parent's conduct with respect to that child was in violation of sections 161.001(1)(D) or (E). The TDPRS need only show that the Appellant's rights were terminated as to her other children based on findings that she violated sections (D) and (E).

Section 161.001(1)(M) does not require the petitioner to prove again the conduct underlying a prior termination decree that found a violation of subsection (D) or (E).

In the Interest of J.M.M. · filed 2002-06-13(1)(M)

We hold that, when a prior decree of termination as to another child is properly admitted into evidence, the TDPRS need not reestablish that the parent’s conduct with respect to that child was in violation of sections 161.001(1)(D) or (E).

Section 161.001(1)(M) permits termination when a parent previously lost parental rights to another child based on conduct described in paragraph (D) or (E), if termination is also in the child's best interest.

in the Interest of S. S. C. · filed 2003-03-18(1)(M)

Next, among the many grounds asserted by the State, one permits termination if the parent has had her parent/child relationship terminated with respect to another child based on a finding that the parent’s conduct violated paragraph (D) or (E) of §161.001(1) of the Family Code or a substantially equivalent law of another state. ... Thus, there appears evidence of record from which the trial court could reasonably form a firm belief or conviction that Calloway had her parental rights terminated with respect to another child based on a finding that she violated paragraph (D) or (E) of the Family Code.

Section 161.001(1)(M) makes a prior termination of parental rights to another child a ground for termination when termination is also in the child’s best interest.

In the Interest of S.M.L.C. · filed 2003-06-25(1)(M)

The evidence is undisputed that Hob-good’s parent-child relationship with her youngest daughter had been terminated for reasons that constitute grounds for termination of her relationship with S.M.L.C. The testimony of the case workers and of Hobgood herself supports the trial court’s finding that Hobgood did not complete her service plan. Either of these grounds is sufficient for termination if that decision is in the best interest of the child.

Section 161.001(1)(M) makes a prior termination of parental rights for conduct violating subsection (D) or (E) a ground for terminating rights to another child.

Taylor v. Texas Department of Protective & Regulatory Services · filed 2005-03-10(1)(M)

As for the first element of section 161.001’s termination standard, there was undisputed and conclusive evidence at trial that Costine’s parental rights to a child other than D.A.C. had been terminated for violations of subsections (D) or (E) of family code section 161.001, which itself is a statutory ground for terminating his rights as to D.A.C.

Section 161.001(1)(M) allows termination based on an earlier termination of parental rights that rested on findings under paragraph (D) or (E), if termination is also in the child’s best interest.

in the Interest of E.W.A., a Child · filed 2008-04-24(1)(M)

The prior termination of a parent-child relationship based on a finding that the parent violated paragraph (D) or (E) of section 161.001(1) is grounds for the subsequent termination of a parent’s relationship with another child. ... Therefore, the evidence is both legally and factually sufficient to support the trial court’s finding in the instant case as to paragraph (M).

Section 161.001(1)(M) permits termination based on a prior termination of parental rights to another child; when the prior decree is admitted, the State need not prove the grounds underlying that decree again.

Espinosa v. Department of Family and Protective Services · filed 2008-10-30(1)(M)

Where, as here, a prior decree of termination as to another child is properly admitted into evidence, the State need not establish the underlying basis for termination, here Section 161.001(1)(D) and (E).

Section 161.001(1)(M) permits termination when the parent’s rights to another child were terminated based on endangerment.

in the Interest of R.S. · filed 2009-10-01(1)(M)

Section 161.001(1)(M) of the Family Code provides as a ground for termination of parental rights a finding that the parent-child relationship was terminated with respect to another child based on a finding of endangerment as set forth in sections 161.001(D) or (E). ... We conclude that this evidence is legally and factually sufficient to support the court’s finding under section 161.001(1)(M).

Section 161.001(1)(M) provides a ground for termination when a parent previously lost parental rights to another child based on conduct under subsection (D) or (E).

in the Interest of D.A.C., a Child · filed 2009-10-27(1)(M)

Furthermore, the evidence presented at trial legally and factually supported the finding that Carpenter had previously had her parental rights terminated with respect to two other children under subsections D and E of §161.001 of the Texas Family Code.

Section 161.001(1)(M) permits termination when a parent’s rights to another child were terminated based on conduct violating Paragraph (D) or (E).

in the Interest of D.P., a Child · filed 2010-02-24(1)(M)

We thus conclude that the evidence is legally and factually sufficient to support the jury’s finding that Michael’s parent-child relationship with respect to another child had been terminated based on a finding that his conduct was in violation of subsection 161.001(1)(D) or (E) of the Family Code.

Subsection (1)(M) permits termination when a parent's rights to another child were previously terminated based on endangerment findings under subsection (1)(D) or (E).

in the Interest of S.A.G., E.J.G., and N.S.G., Children · filed 2010-03-18(1)(M)

Therefore, we hold that the trial court had a legally sufficient basis to support termination under section 161.001(1)(M), and we need not address Mothers’ challenge to the findings under (D) and (E).

Section 161.001(1)(M) allows a prior termination decree based on endangerment to support termination of rights to another child even while the prior decree is on appeal.

in the Interest of A.C., a Child · filed 2012-12-13(1)(M)

We hold that the statute requires no greater finality than this, and accordingly there was legally sufficient evidence to show that the mother had her rights terminated as to other children for purposes of section 161.001(1)(M).

Section 161.001(1)(M) permits termination of parental rights to a child when the parent’s rights to another child were terminated based on conduct violating subsection (D) or (E).

D. M. v. Texas Department of Family and Protective Services · filed 2013-06-14(1)(M)

However, one of the grounds submitted to the jury was section 161.001(M), which allows for the termination of parental rights as to a child if the parent had her parental rights terminated with respect to another child based on a finding that the parent’s conduct was in violation of section 161.001(D) or (E). ... Because the order of termination as to B.A.A. could have been based on section 161.001(1)(M), and because that ground was not challenged on appeal, any error in the trial court’s admission of evidence related to the prior termination proceedings was harmless.

Section 161.001(1)(M) permits termination based on a properly admitted decree terminating the parent’s rights to another child under subsection (1)(D) or (E), without renewed proof of the earlier conduct.

in the Interest of M.L.H.-M., a Child · filed 2014-01-31(1)(M)

It is well established, however, that when a prior decree of termination as to another child is properly admitted into evidence, the Department need not reestablish that the parent’s conduct with respect to that child was in violation of Sections 161.001(1)(D) or (E). ... Therefore, we hold that the evidence is legally and factually sufficient to support termination of V.H.’s parental rights under Section 161.001(1)(M).

Section 161.001(1)(M) permits termination when a parent’s rights to another child were terminated based on conduct violating subsection (D) or (E); a certified copy of that order can establish the ground by clear and convincing evidence.

in the Interest of S.D.S., a Child · filed 2014-02-06(1)(M)

The certified copy of the court order of termination of the mother’s parental rights to a child other than S.D.S. constitutes clear and convincing evidence sufficient to support the trial court’s finding under Section 161.001(1)(M).