Tex. Fam. Code Ann. § 161.001

A parent’s cocaine use during pregnancy can establish a course of conduct that endangers a child under subsection (1)(E).

in the Interest of J.M., a Child · filed 2009-01-15(1)(E)

Testimony about Mother’s conduct both before and after J.M.’s birth could have led the trial court to reasonably form a firm belief or conviction that Mother engaged in a course of conduct that endangered J.M.’s physical or emotional well-being by her use of cocaine during her pregnancy with J.M. ... Therefore, we conclude that the evidence of endangerment under section 161.001(1)(E) is legally and factually sufficient, and we overrule Mother’s first issue.

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

in the Interest of V.S.R.K, a Child · filed 2009-03-19(1)(E)

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

Termination for endangerment requires a voluntary, deliberate, and conscious course of conduct; a single act or omission is insufficient.

In the Interest of C.A.B. · filed 2009-04-02(1)(E)

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

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

in Re David Matthew Layton, Relator · filed 2009-04-03(1)(E)

Looking at all the evidence in the light most favorable to the jury’s finding, however, we conclude a reasonable trier of fact could have formed a firm belief that the father engaged in a course of conduct that endangered B.W.B.’s physical or emotional well-being, thus supporting termination under subsection E.

Section 161.001(1)(E) permits an endangerment finding based on a parent’s conduct before the child’s birth, including drug use and its effect on the parent’s ability to parent.

in the Interest of J.O.A., T.J.A.M., T.J.M., and C.T.M., Children · filed 2009-05-01(1)(E)

It necessarily follows that the endangering conduct may include the parent’s actions before the child’s birth, while the parent had custody of older children, including evidence of drug usage.

A parent's narcotics use and its effect on the parent's ability to care for a child may qualify as endangering conduct.

In Re J.O.A. · filed 2009-05-01(1)(E)

We accordingly agree that a parent's use of narcotics and its effect on his or her ability to parent may qualify as an endangering course of conduct.

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

In Re CAB · filed 2009-05-21(1)(E)

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

Section 161.001(1)(E) covers a parent's course of conduct that endangers a child, even if the conduct was not directed at the child and caused no actual injury.

Jones v. Texas Department of Family and Protective Services · filed 2009-06-04(1)(E)

Further, while section 161.001(1)(E) requires evidence that a parent's "course of conduct" endangered the child, the parent's actions or failures to act need not have been specifically directed at the child or have actually injured the child or even constituted a concrete threat of injury to the child.

Section 161.001(1)(E) covers a parent’s course of conduct that endangers a child’s physical or emotional well-being, even without actual injury or a concrete threat of injury.

C.B. v. D.S. · filed 2009-06-04(1)(E)

Further, while section 161.001(1)(E) requires evidence that a parent’s “course of conduct” endangered the child, the parent’s actions or failures to act need not have been specifically directed at the child or have actually injured the child or even constituted a concrete threat of injury to the child. ... The evidence is legally and factually sufficient to support the jury’s findings that appellant placed the children in an environment that endangered their well-being, engaged in conduct that endangered them, and failed to comply with a court order setting out necessary actions to regain custody.

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

Walker v. Department of Family and Protective Services · filed 2009-06-18(1)(E)

When viewed in the light most favorable to the judgment, we hold that the evidence was legally sufficient to support the trial court's finding that Walker engaged in a deliberate course of conduct that endangered W.J.W. under section 161.001(1)(E).

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

in the Interest of J. T., a Child · filed 2009-07-16(1)(E)

In reviewing the evidence in the light most favorable to the trial court's finding, we conclude that there is legally sufficient evidence to support the trial court's finding that Robert engaged in conduct that endangered the physical or emotional well-being of J.T. constituting a violation of section 161.001(1)(E) of the family code.

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

In Re Eit · filed 2009-11-05(1)(E)

Based on the evidence before it, we conclude that the trial court could reasonably form a firm belief or conviction that Mother had engaged in conduct that endangered Son's physical or emotional well-being.

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

in the Interest of K.F.K., Children · filed 2009-08-31(1)(E)

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

Section 161.001(1)(E) permits termination when a parent’s course of conduct endangers a child; conduct involving another child before the child’s birth can support that finding.

in the Interest of A.S., a Child · filed 2009-10-28(1)(E)

However, the above evidence is legally and factually sufficient for a reasonable ... factfinder to form a “firm belief or conviction” that Tashawna engaged not just in a single act or omission that endangered A.S.’s physical or emotional well-being, but in a course of conduct that endangered A.S.’s physical or emotional well-being.

Section 161.001(1)(E) identifies conduct endangering a child's physical or emotional well-being as a ground for terminating parental rights.

Dean Warner-Lapasinskas and Jamie Sanders v. Texas Department of Family and Protective Services · filed 2009-12-09(1)(E)

At birth, L.L.L. tested positive for amphetamine and marihuana. This is undisputed evidence that appellants engaged in conduct that had endangered L.L.L.'s physical or emotional well-being. This ground for termination would exist regardless when the final hearing was held, as long as the hearing took place within the statutory deadline.

Section 161.001(1)(E) does not require proof that a parent intended to endanger the child.

Deshann Smith A/K/A Cajuanna Peterson v. Department of Family and Protective Services · filed 2009-12-03(1)(E)

It is not necessary to establish that a parent intended to endanger a child in order to support termination of the parent-child relationship under subsection (E).

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

in the Interest of T.W. and C.W., Children · filed 2009-12-17(1)(E)

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

Section 161.001(1)(E) allows a parent's conduct before knowledge of paternity to support an endangerment finding.

in the Interest of D.W., a Child · filed 2009-12-30(1)(E)

While knowledge of paternity is a prerequisite to a showing of knowing placement of a child in an endangering environment under section 161.001(1)(D), it is not a prerequisite to a showing of a parental course of conduct which endangers a child under section 161.001(1)(E).

Section 161.001(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being; exposure to domestic violence and drug use can support that finding.

L.B. v. Texas Department of Family and Protective Services · filed 2010-04-09(1)(E)

This evidence of exposure to domestic violence and drug use would allow a reasonable fact-finder to form a firm belief or conviction that L.B. engaged in a course of conduct that endangered all three of her children.

Section 161.001(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being; domestic violence can satisfy that ground.

in the Interest of M.F., C.B.F. and E.F., Children · filed 2010-05-13(1)(E)

The record shows that James and Shonda both have engaged in domestic violence that has endangered the physical or emotional well-being of the children.

Section 161.001(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being; repeated absences that create instability and physical abuse can satisfy this ground.

in the Interest of I. J. A. · filed 2010-06-16(1)(E)

The evidence of direct physical abuse would be sufficient to support the trial court’s finding that Casillas engaged in conduct that endangered the children’s physical or emotional well-being .

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

in Re Todd-Warren Altschul · filed 2010-07-07(1)(E)

Viewing all the evidence in the light most favorable to the judgment, we hold that a fact-finder could reasonably have formed a firm belief or conviction that Brandie engaged in conduct that endangered the physical and emotional well-being of T.C. See Tex. Fam. Code Ann . § 161.001(1)(E). The evidence is thus legally sufficient to support the trial court’s termination findings under section E.

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

in the Interest of A.F., K.F. and S.F., Children · filed 2010-08-12(1)(E)

Thus, we hold that the evidence supporting termination under section 161.001(1)(E) of the family code is legally and factually sufficient.

Section 161.001(1)(E) permits termination when a parent fails to protect a child from a situation that exposes the child to the risk of sexual abuse.

Ryan Sylvia and Shannon Sylvia v. Texas Department of Family and Protective Services · filed 2010-04-15(1)(E)

Additionally, a parent's refusal to acknowledge responsibility for the child and protect him or her from a situation that exposes the child to the risk of sexual abuse is grounds for termination of parental rights under subsection (E).

Subsections (1)(D) and (E) allow termination when a child is endangered by the child’s surroundings or by a parent’s conduct.

in the Interest of B.J., a Child · filed 2010-04-15(1)(D), (E)

Applying the appropriate standard for reviewing the legal sufficiency of the evidence, (footnote: 5) we hold that, based upon our review of the record, the evidence is legally sufficient to support the trial court’s endangerment findings regarding Appellant under subsections (D) and (E).

Section 161.001(1)(E) permits termination for endangerment when a parent’s repeated criminal conduct and incarceration jeopardize a child’s physical or emotional well-being, even if the conduct was not directed at the child.

In re V.V. · filed 2010-07-29(1)(E)

A life of crime — based on the number of crimes, the frequency of their commission, and repeated incarcerations over a decade — is evidence from which a reasonable fact finder could infer endangerment to a child committed to the offender’s care. While not conduct directed at his child, such conduct is clear and convincing support for the trial court’s termination decision based on the ground of endangerment because this conduct placed his infant child in jeopardy.

Section 161.001(1)(E) permits termination for conduct that endangers a child's physical or emotional well-being even if the conduct is not directed at the child and the child suffers no injury.

In Re CJO · filed 2010-09-09(1)(E)

The offending conduct does not need to be directed at the child nor does the child actually have to suffer an injury to support a finding under Section 161.001(1)(E). ... The evidence is legally and factually sufficient to support the trial court's finding that C.J.O.'s physical and emotional well-being was endangered.

Section 161.001(1)(E) permits termination for conduct that endangers a child’s physical or emotional well-being even if the conduct was not directed at the child and caused no actual injury.

in the Interest of C.J.O., a Child · filed 2010-09-09(1)(E)

The offending conduct does not need to be directed at the child nor does the child actually have to suffer an injury to support a finding under Section 161.001(1)(E). ... The evidence is legally and factually sufficient to support the trial court’s finding that C.J.O.’s physical and emotional well-being was endangered.

Subsection (1)(E) provides a ground for termination when a parent’s conduct endangers a child’s physical or emotional well-being.

in the Interest of C.L.T. and R.D.T., Children · filed 2010-10-20(1)(E)

Under the applicable standards, the evidence is legally and factually sufficient to support the court’s finding that John engaged in conduct which endangered C.L.T.’s physical or emotional well-being.

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

in the Interest of D.W.W.D. & M.L.B.M., Children · filed 2010-10-21(1)(E)

These facts are sufficient to allow a reasonable juror to form a firm conviction that DeLisle and Massey engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered the physical or emotional well-being of the children. Therefore, the evidence is legally and factually sufficient to establish grounds for termination under Section 161.001(1)(E) of the Texas Family Code.

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

in the Interest of I.L.L. and D.R.M.S., Minor Children · filed 2010-10-26(1)(E)

Accordingly, the evidence is legally and factually sufficient to support the termination of Battershell’s parental rights under section 161.001(1)(E).

Section 161.001(1)(E) allows termination when clear and convincing evidence shows that a parent’s conduct endangered a child’s physical or emotional well being, including a failure to protect the child from sexual abuse.

in the Interest of C. T. and K. T., Children · filed 2010-11-30(1)(E)

The trial court could have found that L.M. ignored signs that C.T. and K.T. were being sexually abused by K.M., refused to believe that K.M. sexually assaulted her children, testified on behalf of K.M., and wrote love letters to K.M. even after he was imprisoned for the sexual assault of C.T. Based on this finding, the trial court also could have determined that L.M. engaged in conduct that endangered the children=s physical or emotional well being.

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

in the Interest of L.D., a Child · filed 2010-12-01(1)(E)

Additionally, viewing the evidence as a whole, we hold that a rational trier of fact could have reasonably formed a firm belief or conviction that Brandie engaged in conduct that endangered the physical and emotional well-being of T.C. See TEX. FAM. CODE ANN. § 161.001(1)(E).

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

In Re VV · filed 2010-09-23(1)(E)

We hold that the evidence sufficiently supports the trial court's firm conviction that this father engaged in a course of conduct that endangered the physical and emotional well-being of the child.

Section 161.001(1)(D) and (E) allow termination for knowingly placing a child in an endangering environment or engaging in an endangering course of conduct, when the evidence meets the clear and convincing standard.

in the Interest of K.B., a Child · filed 2010-10-14(1)(D), (1)(E)

The record contains substantial evidence of subsection (D) environmental endangerment and subsection (E) course of conduct endangerment to the physical or emotional well‑being of K.B.

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

In Re TTF · filed 2010-12-02(1)(E)

The evidence is legally and factually sufficient to support the jury's finding that S.M. engaged in conduct that endangered T.T.F.'s physical or emotional well-being.

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

in the Interest of T.T.F., a Child · filed 2010-12-02(1)(E)

Viewing all the evidence in the light most favorable to the termination judgment, and disregarding all contrary evidence that a reasonable factfinder could disregard, we hold that the evidence is legally sufficient to support a factfinder’s firm conviction or belief that S.M. engaged in conduct that endangered T.T.F.’s physical or emotional well-being.

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

in the Interest of C. C. and S. C., Children · filed 2011-01-19(1)(E)

Therefore, we conclude that the evidence, viewed in the light most favorable to the finding, is sufficiently clear and convincing that a reasonable trier of fact could have formed a firm belief or conviction that C.D.C. engaged in conduct or knowingly placed C.C. and S.C. with persons who engaged in conduct that endangered their physical or emotional well being.

Section 161.001(1)(E) permits termination when a parent's course of conduct, including drug abuse and related criminal activity, endangers a child's physical or emotional well-being.

In Re DO · filed 2011-01-20(1)(E)

As summarized above, the evidence showed that M.O.W. and C.D.O. both engaged in a pattern of extensive drug abuse and related criminal activities that endangered the physical or emotional well-being of the children. Because the evidence supports termination under Section 161.001(1)(E) of the Texas Family Code, we need not discuss the remaining statutory findings.

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

in the Interest of D.O., S.O., and M.L.O., Children · filed 2011-01-20(1)(E)

Because the evidence supports termination under Section 161.001 (1) (E) of the Texas Family Code, we need not discuss the remaining statutory findings.

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

in Re K.B. · filed 2010-12-09(1)(E)

Accordingly, as a reasonable factfinder could have formed a firm belief that B.B. engaged in a course of conduct that endangered the physical or emotional well-being of her other children, the evidence is legally sufficient to support termination of B.B.’s parental rights regarding K.B. under subsection (E).

Section 161.001(1)(E) permits termination based on a parent's course of endangering conduct toward other children, even when the conduct was not directed at the child in the termination proceeding.

Hanselman v. Texas Department of Family and Protective Services · filed 2010-12-09(1)(E)

As explained above, however, the endangering conduct need not be directed at the child who is the subject of removal proceedings, as conduct towards other children may suffice to support a finding of endangerment. See J.C., 151 S.W.3d at 288. Accordingly, as a reasonable factfinder could have formed a firm belief that B.B. engaged in a course of conduct that endangered the physical or emotional well-being of her other children, the evidence is legally sufficient to support termination of B.B.’s parental rights regarding K.B. under subsection (E).

Section 161.001(1)(D) and (E) make endangering conditions and endangering parental conduct grounds for terminating parental rights.

Pruitt v. Texas Department of Family and Protective Services · filed 2010-12-23(1)(D), (1)(E)

Moreover, a reasonable factfinder could have resolved all disputed evidence in the Department's favor and could have reasonably formed a firm belief or conviction that statutory grounds for termination existed under sections 161.001(1)(D) and (E) of the family code.

Section 161.001(1)(E) permits termination when a parent’s illegal drug use exposes a child to the risk that the parent may be impaired or imprisoned.

in the Interest of B.H., a Child · filed 2011-01-13(1)(E)

Third, because it exposes the child to the possibility that the parent may be impaired or imprisoned, illegal drug use may support termination under section 161.001(1)(E).

Repeated cocaine use can support termination under subsections (1)(D) and (E) when it exposes children to endangering conditions or conduct.

in the Interest of R.A.E., M.A.E., A.M.E., D.A.S., B.G.S., and B.A.E., Minor Children · filed 2011-02-17(1)(D), (E)

Accordingly, giving due deference to the trial court’s findings, we hold that a reasonable trier of fact could have formed a firm belief or conviction that Mother engaged in conduct or knowingly placed or knowingly allowed the children to remain in conditions that endangered their physical or emotional well-being.

Section 161.001(1)(D) addresses an endangering environment, while (1)(E) addresses a parent’s endangering course of conduct.

in the Interest of O.E.W.-K., a Child · filed 2011-03-31(1)(D), (1)(E)

We thus hold that the evidence is legally sufficient to support termination of Mother’s parental rights to O.E.W.-K. under subsections (D) and (E).

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

in the Interest of C.D. and K.D., Children · filed 2011-05-05(1)(E)

Additionally, termination under (E) must be based on more than a single act or omission; the statute requires a voluntary, deliberate, and conscious course of conduct by the parent. ... We hold there is legally and factually sufficient evidence that Father endangered the children’s physical well-being and that there is legally sufficient evidence that Mother endangered the children’s physical well-being.

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

in the Interest of M.E.-M.N, Minor Child · filed 2011-05-26(1)(E)

Viewing all the evidence in the light most favorable to the termination judgment, and disregarding all contrary evidence that a reasonable fact finder could disregard, we hold that the evidence is legally sufficient to support a fact finder‘s firm conviction or belief that Appellant engaged in conduct that endangered M.E.-M.N.‘s physical or emotional well-being.

Section 161.001(1)(E) provides an endangerment ground for termination when a parent's conduct jeopardizes a child's emotional well-being.

In Re JKF · filed 2011-07-14(1)(E)

Viewing the evidence in the light most favorable to the termination order, we conclude the evidence is legally sufficient to establish the requisites under section 161.001(1)(E) because a reasonable factfinder could have formed a firm belief or conviction that Mother engaged in conduct which endangered the emotional well-being of the child.

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

In the Interest of J.K.F. · filed 2011-07-14(1)(E)

Viewing the evidence in the light most favorable to the termination order, we conclude the evidence is legally sufficient to establish the requisites under section 161.001(1)(E) because a reasonable factfin-der could have formed a firm belief or conviction that Mother engaged in conduct which endangered the emotional well-being of the child.

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

In Re Me-Mn · filed 2011-06-16(1)(E)

Viewing all the evidence in the light most favorable to the termination judgment, and disregarding all contrary evidence that a reasonable fact finder could disregard, we hold that the evidence is legally sufficient to support a fact finder's firm conviction or belief that Appellant engaged in conduct that endangered M.E.-M.N.'s physical or emotional well-being.

Subsections (1)(D) and (E) address endangerment caused by a child’s surroundings and by a parent’s conduct, respectively.

in the Interest of J.G.K., a Child · filed 2011-06-23(1)(D), (1)(E)

We therefore hold that the evidence is factually sufficient to support termination of Mother’s parental rights to J.G.K. under subsections (D) and (E).

Section 161.001(1)(E) allows a court to consider a parent’s abuse of another child in the family when deciding whether the parent endangered the child whose rights are at issue.

in the Interest of H.N.J., J.M.S., J.A.R., J.A.R., and J.R., Children · filed 2011-07-13(1)(E)

However, the manner in which a parent treats other children in the family can be considered in deciding whether that parent engaged in a course of conduct that endangered the physical or emotional well-being of a child.

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

in the Interest of A.M.M., A.N.M., E.J.M., A.E.E., and B.T., Children · filed 2011-11-03(1)(E)

These facts are sufficient to allow a reasonable trier of fact to form a firm belief or conviction that John engaged in a voluntary, deliberate, and conscious course of conduct that endangered the physical or emotional well-being of A.M.M., A.N.M., and E.J.M. Therefore, the evidence is legally and factually sufficient to support termination under Section 161.001(1)(E) of the Texas Family Code.

Section 161.001(1)(D) and (E) allow termination when a parent knowingly permits endangering conditions or engages in conduct that endangers a child; continued heroin and cocaine use can support those findings.

in the Interest of C.S.L.E.H. and C.H.H., Jr., Children · filed 2011-08-25(1)(D), (1)(E)

We hold that the evidence is legally and factually sufficient to support the trial court’s family code section 161.001(1)(D) and (E) findings, and we overrule Father’s first issue.

Section 161.001(1)(E) allows repeated exposure to domestic violence and continued contact with an abusive partner to support a finding that a parent endangered a child’s physical or emotional well-being.

LeShore v. Texas Department of Family and Protective Services · filed 2011-11-10(1)(E)

In light of the preceding, regardless of whether the evidence is viewed in the light most favorable to the trial court's ruling, we must conclude that a reasonable trier of fact could have formed a firm belief or conviction that LeShore had engaged in conduct or knowingly placed her children with persons who had engaged in conduct that endangered their physical or emotional well-being.

Section 161.001(1)(D) and (E) permit endangerment findings based on prenatal drug use and a continuing course of conduct that endangers a child after birth.

in the Interest of B.R., a Child · filed 2011-11-10(1)(D), (E)

Mother’s testimony about her conduct before and after B.R.’s birth could have led the trial court to reasonably form a firm belief or conviction that she knowingly placed or knowingly allowed B.R. to remain in conditions or surroundings that endangered his physical well-being while in the womb, and that she engaged in a course of conduct that endangered his emotional well-being after his birth.

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

in the Interest of N. D. B., a Child · filed 2011-11-29(1)(E)

We find the evidence sufficient to support the trial court's finding that appellant engaged in conduct or knowingly placed N.D.B. with persons who engaged in conduct which endangered the child's physical or emotional well-being, under section 161.001(1)(E).

Section 161.001(1)(E) permits termination when a parent's course of abuse toward other family members endangers a child, even if the abuse is not directed at that child.

in the Interest of L.N.C. and I.G.H. · filed 2012-03-06(1)(E)

B.J.H.'s good intentions notwithstanding, the evidence demonstrated a voluntary, deliberate and conscious "course of conduct" of physical abuse and anger toward A.B.H. and L.N.C. which could impact the well-being of I.G.H. ... Based upon this record, we conclude the evidence is legally and factually sufficient to support termination of B.J.H.'s parental rights under section 161.001(1)(E).

Section 161.001(1)(E) allows a parent’s sexual abuse of one child to establish endangerment of other children in the home.

in the Interest of E.G., Minor Children · filed 2012-02-29(1)(E)

Looking at the evidence in the light most favorable to the jury’s finding, we therefore hold the evidence is legally sufficient to permit the jury to form a firm belief or conviction that, under subsection 161.001(1)(E), Alfonso’s sexual abuse of Y.G. endangered the physical or emotional well-being of C.G., V.G., S.G., and D.G.

Section 161.001(1)(E) requires a voluntary, deliberate, and conscious course of parental conduct that endangers a child; a single act or omission does not suffice.

in the Interest of A.W. · filed 2012-03-22(1)(E)

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

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

May v. Texas Department of Family and Protective Services · filed 2012-04-19(1)(E)

While many of these actions taken in isolation might not warrant termination of T's parental rights, we conclude that, taken collectively, they comprise a record containing legally and factually sufficient evidence on which reasonable jurors could find by clear and convincing evidence that T's acts and omissions endangered the children's emotional and physical well-being.

Section 161.001(1)(E) does not require proof that a parent used drugs in front of the children to support termination for endangering conduct.

in the Interest of A.H.A., M.O.A., D.J.A., E.A.A.A., J.J.A.A., L.E.F., R.E.F., and J.C.R., Children · filed 2012-04-26(1)(E)

Moreover, the Department was not required to prove that Mother used drugs in front of her children to support a finding of termination under section 161.001(1)(E).

Section 161.001(1)(E) permits termination when clear and convincing evidence shows a parent’s conduct endangered a child’s physical or emotional well-being; later evidence may establish endangerment before removal.

L.F. v. Department of Family and Protective Services · filed 2012-05-03(1)(E)

Thus, the medical evidence and evidence of incidents occurring after the children had been removed from appellant’s custody is relevant as establishing appellant’s mental health problems and that she actually endangered her children before this removal.

Section 161.001(1)(E) permits consideration of endangering parental conduct before and after a child's birth, without limiting when the conduct occurred.

A. H. and J. R. v. Texas Department of Family and Protective Services · filed 2012-05-18(1)(E)

But subsection (E) of section 161.001 does not require the endangerment to have occurred during a certain time period, see Tex. Fam. Code Ann. § 160.001(1)(E), and the court "may look to parental conduct occurring both before and after the child's birth." In re M.E.-M.N. , 342 S.W.3d at 262 (citing In re D.M. , 58 S.W.3d 801, 812 (Tex. App.--Fort Worth 2001, no pet.)).

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

in the Interest of M.A.P., Minor Child · filed 2012-06-07(1)(E)

We therefore hold that the evidence is legally and factually sufficient to sustain the jury’s termination verdict against Mother to the extent that the verdict rests on the ground for termination described by section 161.001(1)(E), and we overrule Mother’s second issue.

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

in the Interest of I.D.J. · filed 2012-06-14(1)(E)

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

Subsection (1)(E) permits termination when a parent’s conduct, or knowing placement of a child with someone whose conduct endangers the child’s physical or emotional well-being, is proved by factually sufficient evidence.

in the Interest of A.J.M. and E.A.M., Children · filed 2012-07-16(1)(E)

Applying the appropriate standard of review, see In re H.R.M., 209 S.W.3d 105, 108 (Tex. 2006), we hold that the trial court could have reasonably formed a firm conviction or belief that appellant engaged in conduct or knowingly placed his daughters with persons who engaged in conduct which endangered their physical or emotional well-being, and we therefore hold that the evidence is factually sufficient to support termination on that ground. See Tex. Fam. Code Ann. § 161.001(1)(E) (West Supp. 2011).

Section 161.001(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being, including through exposure to recurring domestic violence.

L.M. and Y.Y. v. Department of Family and Protective Services · filed 2012-07-12(1)(E)

Given the record, we conclude that the evidence, viewed in the light most favorable to the subsection 161.001(1)(E) finding, was sufficiently clear and convincing that a reasonable fact finder could have formed a firm belief or conviction that Appellants engaged in conduct or knowingly placed the children with persons who engaged in conduct which endangers the physical or emotional well-being of the children. ... Accordingly, we hold that the evidence was legally and factually sufficient to support the section 161.001(1)(E) finding as to each parent.

Section 161.001(1)(E) makes a parent’s voluntary course of conduct that endangers a child’s physical or emotional well-being a ground for termination.

in the Interest of E.P.C., a Child · filed 2012-08-30(1)(E)

Viewing all the evidence in the light most favorable to the termination judgment, and disregarding all contrary evidence that a reasonable factfinder could disregard, we hold that the evidence is legally sufficient to support a factfinder’s firm conviction or belief that Father engaged in conduct that endangered E.P.C.’s physical or emotional well-being.

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

in the Interest of C.J.S and S.G.B., Jr., Children · filed 2012-09-20(1)(E)

Termination must be based on more than a single act or omission; a voluntary, deliberate, and conscious course of conduct by the parent is required. ... Accordingly, we conclude that the evidence is legally and factually sufficient to support the trial court‟s finding that Latasha engaged in conduct under subsection (E) that endangered the emotional well-being of her children.

Section 161.001(1)(E) permits termination based on a deliberate course of conduct that endangers a child, including violent acts committed before the child’s birth.

In the Interest of S.M., a Child · filed 2012-09-26(1)(E)

Even though all of these offenses occurred before S.M. was born, they can still be considered as part of a voluntary, deliberate, and conscious course of conduct that had the effect of endangering S.M. ... Thus, the evidence is factually sufficient to support the trial court’s termination finding on the Section 161.001(1)(E) ground.

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

in the Interest of A.H., a Child · filed 2012-09-27(1)(E)

We hold that under the applicable standards of review, considering all of the facts described above, the evidence is legally and factually sufficient to sustain the trial court’s finding that Mother engaged in conduct that endangered Andy’s physical or emotional well-being.

Section 161.001(1)(E) permits termination when a parent's failure to obtain necessary medical training, despite repeated warnings, endangers a child's physical well-being.

in Interest of S.R., a Child · filed 2012-09-27(1)(E)

While Mother did not cause S.R. to need a tracheotomy, the jury could have determined, as the jury did in J.O.C. , that Mother endangered S.R. through her failure to obtain the appropriate medical training despite repeated admonitions, instructions, and warnings during the eleven months following S.R.’s removal.

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

in the Interest of D.M.L., a Child · filed 2012-10-31(1)(E)

Having reviewed the record as a whole, including the evidence summarized above, we hold that the evidence is legally and factually sufficient for the jury to form a firm belief or conviction that Jason engaged in conduct which endangered D.M.L.’s physical or emotional well-being. See TEX. FAM. CODE ANN. § 161.001(1)(E) (West Supp. 2012).

Section 161.001(1)(E) covers parental omissions or failures to act when they endanger a child.

in the Interest of K.A., and L.A., Children · filed 2012-11-15(1)(E)

This section refers not only to the parent's acts, but also to the parent's omissions or failures to act. ... We decline to apply Angela’s interpretation of the statute.

Section 161.001(1)(E) permits an endangering conduct question to be submitted to the jury when more than a scintilla of evidence supports it; abuse of prescription drugs and illegal drug use may supply that evidence.

in the Interest of S.I.-M.G. and S.B.G.-R., the Children · filed 2012-11-15(1)(E)

We therefore hold that more than a scintilla of evidence exists to support the submission of the section 161.001(1 )( E) endangering conduct question to the jury.

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

K. M. v. Texas Department of Family and Protective Services · filed 2012-11-19(1)(E)

Because we conclude the evidence is legally and factually sufficient to support the trial court’s finding under Section 161.001(1)(E) as challenged in Issue Two, we need not address Kari’s remaining sufficiency challenges relating to Section 161.001(1) as raised in Issues Two, Three, and Four.

A parent’s continued criminal conduct can satisfy section 161.001(1)(E) when it contributes to a dangerous environment for the child.

in the Interest of Y.F.J. and S.E.J., Children · filed 2012-11-29(1)(E)

We agree with Father’s attorney that there are no arguable grounds for an appeal because the evidence shows that Father’s continued criminality has contributed to the dangerous environment in which the children lived, thereby meeting the section 161.001(E) grounds for termination.

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

in Re S.B.B · filed 2012-12-06(1)(E)

Based upon the evidence that appellant had been incarcerated for at least two significant periods of time during the child’s life (the first arising from his 2006 felony conviction and the second from his 2010 felony arrest and “blue warrant” while on parole), as well as the mother’s testimonial assertion that appellant was involved in the manufacture of methamphetamine, the trial court, acting as fact finder, could have reasonably found that appellant had engaged in conduct that endangered the physical or emotional well-being of the child. See TEX. FAM. CODE ANN. § 161.001(1)(E).

Section 161.001(1)(E) allows a court to consider persistent drug use, inconsistent visitation, and financial instability when deciding whether a parent endangered a child's physical or emotional well-being.

in the Interest of R.M., C.C., C.C., P.C., A.C., B.O.C. and K.C., Children · filed 2012-12-11(1)(E)

Based on evidence that Christy continued to use drugs, failed to maintain consistent visitation or financial stability, and failed to make any discernible effort to improve her life in such a way that she might obtain the return of her children, the trial court could have formed a firm belief or conviction that Christy endangered the physical or emotional well-being of the children. We conclude that legally and factually sufficient evidence supports the trial court's finding of a predicate act or omission supporting termination of Christy's parental rights.

Section 161.001(1)(E) permits termination when a parent's continuing course of conduct places a child in conditions that endanger the child's physical or emotional well being, even without proof that the parent personally inflicted the child's injuries.

in the Interest of B. M. A. J., a Child · filed 2012-12-20(1)(E)

Regardless of whether J.S. inflicted the injuries B.M.A.J. suffered as an infant and young child, the evidence is legally sufficient to show that J.S. engaged in a continuous course of conduct in which she again placed B.M.A.J. in conditions or surroundings that subjected him to physical and emotional harm. ... We conclude the evidence is legally sufficient to support termination of J.S.’s parental rights under subsection (E).

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

in the Interest of S.K.V and T.A v. Children · filed 2013-01-02(1)(E)

Therefore, we hold the evidence is sufficient to support the trial court’s finding under subsection (E) of section 161.001(1).

Section 161.001(1)(E) allows termination when a parent’s conduct endangers a child’s physical or emotional well-being; continued drug use, inconsistent visitation, and financial instability can support that finding.

State of Texas v. Roades · filed 2012-12-11(1)(E)

Based on evidence that Christy continued to use drugs, failed to maintain consistent visitation or financial stability, and failed to make any discernible effort to improve her life in such a way that she might obtain the return of her children, the trial court could have formed a firm belief or conviction that Christy endangered the physical or emotional well-being of the children.

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

in the Interest of J.E., a Child · filed 2013-02-05(1)(E)

Vickie's pattern of drug use and involvement with drug users, including her admitted methamphetamine use while pregnant, permitted the trial court to form a firm belief or conviction that she engaged in conduct endangering J.E.'s physical or emotional well-being.

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

in the Interest of H.D.B.M., a Child · filed 2013-02-28(1)(E)

The predicate condition of section 161.001(1)(E) is satisfied if the parent has “engaged in conduct . . . which endangers the physical or emotional well-being of the child.” ... As such, we hold that the evidence is legally sufficient to support the determination that Browne engaged in conduct proscribed by subsection (E) of section 161.001(1).

Section 161.001(1)(E) permits termination when a parent's conduct endangers a child's physical or emotional well-being; repeated criminal conduct, domestic violence, and prolonged absence can support that finding.

in the Interest of A.G., J.G., P.G., S.G. and A.G., Children · filed 2013-03-07(1)(E)

Here, Gutierrez’s continual engagement in criminal misconduct resulting in numerous prison terms, his repeated assaults upon the mother of the children which were witnessed by the children, his sexual assault upon a minor, the lack of a strong parental bond between parent and child, his separation from the children for long periods of time, his decision to leave the children with their mother who eventually abandoned them, his failure to comply with the Department’s service plan, and his failure to pay child support constitute both legally and factually sufficient evidence supporting the determination that Gutierrez engaged in conduct endangering the physical or emotional well-being of the children.

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

Ron Valentine v. State · filed 2013-03-07(1)(E)

Here, Gutierrez's continual engagement in criminal misconduct resulting in numerous prison terms, his repeated assaults upon the mother of the children which were witnessed by the children, his sexual assault upon a minor, the lack of a strong parental bond between parent and child, his separation from the children for long periods of time, his decision to leave the children with their mother who eventually abandoned them, his failure to comply with the Department's service plan, and his failure to pay child support constitute both legally and factually sufficient evidence supporting the determination that Gutierrez engaged in conduct endangering the physical or emotional well-being of the children.

Subsection (1)(E) allows a finding of endangering conduct based on a parent’s repeated criminal acts and resulting absence from the child’s life, even if the parent never had possession of the child.

in the Interest of S.L.-E.A. · filed 2013-03-21(1)(E)

Here, the fact that Father was not present when S.L.-E.A. was removed and never had possession of S.L.-E.A. does not preclude the trial court’s finding of endangering conduct; a child’s emotional well-being can be negatively affected when parents repeatedly commit criminal acts that subject them to incarceration that results in their being absent from the child’s life and unable to provide support, thus creating an emotional vacuum in the child’s life and subjecting the child to ongoing uncertainty regarding who will care for him.

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

in the Interest of B.R., B.R., and B.E.R., Children · filed 2013-01-04(1)(E)

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

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

in the Interest of K.R.G., a Child · filed 2013-03-21(1)(E)

Under subsection (E), the relevant inquiry is whether clear and convincing evidence exists to show that the parent engaged in conduct or knowingly placed the child with persons who engaged in conduct that endangered the child’s physical or emotional well-being.

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

In the Interest of T.G.R.-M. · filed 2013-03-21(1)(E)

We hold instead that the evidence, viewed in accord with the applicable standards of review, is legally and factually sufficient to support the trial court’s firm conviction that the mother engaged in a course of conduct that endangered the physical and emotional well-being of T.G.R.-M.

A parent’s cocaine use during pregnancy and after the child’s removal can support an endangerment finding under section 161.001(1)(E).

in the Interest of Z. L. W. v. Department of Family and Protective Services · filed 2013-01-31(1)(E)

The evidence of all of this conduct supports a finding of endangerment in the relevant sense under section 161.001(1)(E).

Repeatedly failing to ensure that a medically fragile child attends necessary medical appointments can support termination for endangering conduct.

in the Interest of C.D.F., Child · filed 2013-03-26(1)(E)

We conclude a reasonable factfinder could form a firm belief or conviction in the department’s allegations because (1) Davis failed to ensure that C.D.F. attended his medical appointments; (2) she knowingly placed him with a nurse who was not taking him to his medical appointments; and (3) missing those ... appointments jeopardized C.D.F.’s physical well-being.

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

in the Interest of B. H., C. H., and D. H., Children · filed 2013-04-03(1)(E)

The disputed evidence at trial did not call into question the fact that A.H. engaged in a course of conduct that was endangering to her children before and after their birth. The evidence also shows that A.H. did not abandon the endangering conduct that contributed to her children’s removal. Thus, the evidence is factually sufficient to support termination of A.H.’s parental rights under subsection (E).

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

in Re H.D., a Child · filed 2013-05-09(1)(E)

We hold that the evidence was legally and factually sufficient to support the trial court’s termination of M.D.’s parental rights pursuant to section 161.001(1)(E).

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

in the Interest of S. B. and T. B., Jr., Children · filed 2013-05-22(1)(E)

We hold that the evidence is legally and factually sufficient to support termination of K.B. and T.B.’s parental rights under Section 161.001(1)(E).

Section 161.001(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being; domestic violence, drug use, and physical discipline that leaves bruises can support that finding.

in the Interest of K.A.F., D.A.F. and A.L.F. · filed 2013-06-14(1)(E)

Viewing these facts under the appropriate standard of review, we conclude a reasonable fact finder could form a firm belief or conviction that Mother’s violent relationships with Father and B.D., continued marijuana use, and “whippings” resulting in bruises endangered the children.

Section 161.001(1)(D) and (E) allow termination when a parent leaves a child in a home where violent conduct endangers the child.

in the Interest of A. v. M., A. S., and A. S., Minor Children · filed 2013-05-09(1)(D), (1)(E)

Evidence that a parent does not remove a child from, or allows a child to remain in a home where there is violent conduct, supports termination under section 161.001 (1) (D) and (E) of the Texas Family Code.

Section 161.001(1)(D) and (E) permit termination when a parent knowingly exposes children to endangering surroundings or follows a course of conduct that endangers them, including by failing to protect them from known abuse.

in the Interest of A.W. and H.W., Jr., Children · filed 2013-05-09(1)(D), (1)(E)

We conclude and hold that there is sufficient evidence from which a factfinder could reasonably conclude that Mother was well aware of Father’s propensity to lose control when disciplining the children and that she nevertheless continued to allow him access to them.

Subsection (1)(E) supports termination when the evidence shows a course of conduct endangering the children’s physical or emotional well-being.

in the Interest of H.L.B., T.K.B. & C.L.B. Children · filed 2013-07-23(1)(E)

Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that appellant engaged in a course of conduct that endangered the physical or emotional well-being of the children.

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

in the Interest of A.R.F., a Child · filed 2013-07-25(1)(E)

We therefore hold that the evidence is legally and factually sufficient to support the trial court‘s endangering conduct finding as to Father.

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

in the Interest of J.A.L. and M.N.L., Children · filed 2013-08-01(1)(E)

To support termination under Section 161.001(1)(E), the offending conduct does not need to be directed at the child, nor does the child actually have to suffer an injury.

Section 161.001(1)(E) permits termination for endangering conduct even when the conduct was not directed at the child and the child suffered no injury.

in the Interest of S.L.W., a Child · filed 2013-08-08(1)(E)

To support a finding of endangerment, the parent’s conduct does not necessarily have to be directed at the child, and the child is not required to suffer injury.

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

in the Interest of A.B. and H.B., Children · filed 2013-08-08(1)(E)

Therefore, based on the foregoing and giving due deference to the jury’s determinations of credibility and the weight of the evidence, we conclude that the evidence is also factually sufficient to support the endangerment finding under section 161.001(1)(E).

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

in the Interest of A.G. · filed 2013-08-28(1)(E)

Because we have concluded there is both legally and factually sufficient evidence to support a finding under section 161.001(1)(E), we do not address Arthur’s remaining complaints regarding the sufficiency of the evidence under sections 161.001(1)(D), (N), and (Q).

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

in the Interest of J. M. and Z. M., Children · filed 2013-10-16(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to support termination of K.S.’s parental rights under Section 161.001(1)(E).

Section 161.001(1)(D) and (E) allow termination when a parent knowingly exposes a child to endangering conditions or engages in conduct that endangers the child’s physical or emotional well-being.

in the Interest of M.C.D. and J.N.D., Children · filed 2013-07-18(1)(D), (1)(E)

Accordingly, giving due deference to the trial court’s findings, we hold that the trial court could have formed a firm belief or conviction that Mother engaged in conduct and knowingly placed or knowingly allowed the children to remain in conditions that endangered their physical or emotional well-being.

Section 161.001(1)(E) supports termination when a parent engages in conduct or knowingly places a child with people whose conduct endangers the child’s well-being.

in the Interest of J.L., a Child · filed 2013-07-18(1)(E)

We conclude that a reasonable factfinder could have formed a firm belief or conviction that Mother engaged in conduct or knowingly placed J.L. with persons who engaged in conduct that endangered J.L.’s physical or emotional well-being.

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

in the Interest of C.M., J.G., and A.G., Children · filed 2013-08-29(1)(E)

The evidence is legally and factually sufficient to support the finding that Theresa endangered the physical or emotional well-being of the children.

Section 161.001(1)(E) permits termination when a parent’s criminal conduct and lack of contact endanger a child’s physical or emotional well-being.

in the Interest of A.J.D., a Child · filed 2013-10-24(1)(E)

Because Father’s criminal conduct and his lack of contact with Abby while he was not confined eliminated his physical presence from her life, restricted any emotional connection that could have been made with her, and deprived her of parental care and protection, we conclude, based on our review of the entire record, that the evidence is legally and factually sufficient to support the trial court’s finding that he knowingly engaged in conduct that endangered her physical or emotional well-being.

Section 161.001(1)(E) permits termination when a parent knowingly places children with someone whose conduct endangers their physical or emotional well-being.

in the Interest of L.M. and E.M. · filed 2013-11-07(1)(E)

Knowing that his wife was abusing drugs and alcohol, and knowing that she would drive with the children in the car, T.M. left the children in her care. The trial court could rationally form a firm conviction or belief that T.M. knowingly placed the children with a person who engaged in conduct which endangers the children’s physical or emotional well-being. See Tex. Fam. Code Ann. § 161.001(1)(E).

Section 161.001(1)(E) permits termination for conduct that endangers a child’s physical or emotional well-being, even if the conduct is not directed at the child and the child suffers no injury.

in the Interest of K.L.E.C., a Child · filed 2013-11-14(1)(E)

We hold that the evidence is legally and factually sufficient to support the trial court’s finding under Section 161.001(1)(E). ... To support termination under Section 161.001(1)(E), the offending conduct does not need to be directed at the child, nor does the child actually have to suffer an injury.

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

in the Interest of V.U., V.H., A.M. U.C., AKA C.U. and I.N., AKA N.I.N. · filed 2013-11-20(1)(E)

Accordingly, the evidence was legally and factually sufficient to support the trial court’s finding that termination was proper under section 161.001(1)(E).

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

in the Interest of L. K., a Child · filed 2013-12-04(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to support termination of F.T.’s parental rights under Section 161.001(1)(E).

Section 161.001(1)(E) permits termination when a parent knowingly places a child with someone whose conduct endangers the child’s physical or emotional well-being.

D. G. v. Texas Department of Family and Protective Services · filed 2013-12-05(1)(E)

She has knowingly allowed Dawn to have contact with Father and, as a result, she has placed her daughter with someone who has engaged in conduct which endangers the physical or emotional well-being of the child.

Section 161.001(1)(E) permits termination when a parent’s drug activity and repeated incarceration form a course of conduct that endangers the child’s well-being.

in the Interest of J.A.L., a Child · filed 2013-12-19(1)(E)

The trial court’s finding under Section 161.001(1)(E) is supported by the record. There was clear and convincing evidence from which the trial court could reasonably have formed a firm belief that Appellant engaged in a course of conduct that endangered the physical or emotional well-being of J.A.L.

Section 161.001(1)(E) allows termination for endangering conduct even if the conduct was not directed at the child and the child suffered no injury.

in the Interest of A.G., J.G., M.F., and B.F., Children · filed 2013-12-20(1)(E)

Such acts constituted conduct that endangered the children. To support termination under Section 161.001(1)(E), the offending conduct does not need to be directed at the child, nor does the child actually have to suffer an injury.

Section 161.001(1)(E) permits termination for endangering conduct even when the conduct is not directed at the child and the child suffers no actual injury.

in the Interest of R.H. II, A.H., and K.L.H., Children · filed 2014-01-24(1)(E)

To support termination under Section 161.001(1)(E), the offending conduct does not need to be directed at the child, nor does the child actually have to suffer an injury.

Section 161.001(1)(E) supports termination when the evidence establishes endangering conduct.

in the Interest of J. N. G., a Child · filed 2014-01-31(1)(E)

Therefore, we hold that the evidence is factually sufficient to support termination of J.S.G.’s parental rights under Section 161.001(1)(E).

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

in the Interest of K.L., B.L. & B.L., Children · filed 2014-02-19(1)(E)

Viewing the evidence in the light most favorable to the finding, we conclude that the trial court reasonably could have found that M.L. and B.R.’s methamphetamine use was voluntary, deliberate, and conscious; that it subjected the children to a life of uncertainty and instability; and that it endangered the children’s physical and emotional well-being. ... Therefore, we hold that the evidence is legally and factually sufficient to support termination of M.L.’s and B.R.’s parental rights under Section 161.001(1)(E).

Subsection (1)(E) requires clear and convincing evidence of a parent's course of conduct that endangers a child's physical or emotional well-being.

in the Interest of J.D.B. and T.T.B., Minor Children · filed 2014-02-28(1)(E)

Based on the record in this case, we hold that the evidence is legally and factually sufficient to support the trial court’s finding under Section 161.001(1)(E).

Section 161.001(1)(E) supports termination when the evidence shows parental conduct endangering the child’s physical or emotional well-being.

in the Interest of M. M., a Child · filed 2014-03-06(1)(E)

Applying these rules to the present case, we find the evidence legally and factually sufficient to support the trial court’s finding that Mother engaged in conduct that endangered M.M.’s physical or emotional well-being.

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

in the Interest of B.J.A., a Child · filed 2014-04-02(1)(E)

The record before us contains clear and convincing evidence from which a fact finder could reasonably determine that T.A. and C.K. committed acts within the parameters of § 161.001(1)(E) of the Family Code and that termination was in the best interest of the children.

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

in the Interest of R.T.M., Jr., a Child · filed 2014-04-03(1)(E)

Based on the record in this case, we hold that the evidence is legally and factually sufficient to support the trial court’s finding under Section 161.001(1)(E).

Subsection (1)(E) supports termination when the evidence establishes endangering conduct.

in Re T. E. G. and E. A. G., Children · filed 2014-05-08(1)(E)

We hold that the evidence was legally and factually sufficient to support the trial court’s termination of P.M.’s parental rights pursuant to section 161.001(1)(E).

Section 161.001(1)(E) permits termination for conduct that endangers a child's emotional well-being even if the conduct is not directed at the child or causes no actual harm.

in the Interest of R.M., N.M., N.M., and K.O., Children · filed 2014-02-20(1)(E)

The statute does not require that conduct be directed at a child or cause actual harm; rather, it is sufficient if the conduct endangers the emotional well-being of the children.

Section 161.001(1)(E) permits termination for conduct endangering a child’s physical or emotional well-being, but disputed evidence about a parent’s absence may fail to establish that ground as a matter of law.

Alexandra Burns v. Burns · filed 2014-04-10(1)(E)

Because the parties disputed both the reasons for, and effect of, Michael’s absence from M.A.’s life, we hold Alexandra cannot establish that Michael’s rights must be terminated as a matter of law.

Section 161.001(1)(E) permits termination when a parent knowingly places a child with someone whose conduct endangers the child’s physical or emotional well-being.

J. D. v. Texas Department of Family and Protective Services · filed 2014-04-24(1)(E)

Legally and factually sufficient evidence supports the jury’s implied finding that appellant knowingly placed G.W. with someone whose conduct endangered G.W.’s physical or emotional well-being.

The evidence was legally and factually sufficient to support termination under subsection (1)(E).

in the Interest of K. G. and A. G., Children · filed 2014-05-14(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to support termination of J.W.’s parental rights under Section 161.001(1)(E).

The evidence was legally and factually sufficient to support termination under subsection (1)(E).

in the Interest of S. M., M. M., and J. M., Children · filed 2014-06-25(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to support termination of K.M.’s parental rights under Section 161.001(1)(E).

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

in the Interest of N.B. and J.B., Children · filed 2014-07-02(1)(E)

This is sufficient clear and convincing evidence of a continuing course of conduct by appellant endangering the emotional and physical well-being of the children.

Subsection (1)(E) permits termination when a parent’s knowing failure to protect a child from the mother’s drug abuse during pregnancy forms part of a course of endangering conduct.

in the Interest of J.W.S., F.S., Children · filed 2014-07-02(1)(E)

Scoggins’ omission—the failure to take any action to protect F.S. from Smith’s drug abuse—which occurred throughout Smith’s pregnancy, was both legally and factually sufficient to support the trial court’s finding that Scoggins engaged in conduct that endangered F.S.

Section 161.001(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being; drug use while caring for young children and leaving them home alone can support that finding.

in the Interest of M.H., A.H., and D.W. H., III, Children · filed 2014-07-10(1)(E)

The evidence showed that the mother took illegal substances while responsible for the care of the children and that she left her young children home alone while she went out and partied. Based on the record in this case, we hold that the evidence was legally and factually sufficient to support the trial court’s finding under Section 161.001(1)(E).

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

B. L. M. v. J. H. M., Iii · filed 2014-07-17(1)(E)

We further conclude that even considering the disputed evidence, the trial court could have formed a firm conviction or belief that Beth had engaged in a course of conduct that endangered the children’s physical or emotional well-being.

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

in the Interest of K.L.C., L.M.C., P.D.C., and T.A.C., Children · filed 2014-07-17(1)(E)

Such acts constituted a course of conduct that endangered the child. The evidence is legally and factually sufficient to support the trial court’s finding as to the father under Section 161.001(1)(E).

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

in the Interest of B.P., a Child · filed 2014-07-25(1)(E)

Use of K2 and excessive consumption of alcohol by A.P. demonstrates he engaged in more than a single act of conduct which could endanger B.P.’s physical and emotional well-being.

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

in the Interest of K.S., C.S., and C.S, the Children · filed 2014-08-07(1)(E)

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

Section 161.001(1)(E) requires endangerment of a child’s physical well-being to result directly from the parent’s conduct, including acts, omissions, or failures to act.

in the Interest of L.M.F., a Child · filed 2014-05-29(1)(E)

Under subsection (E), the relevant inquiry is whether evidence exists that the endangerment of the child’s physical well-being was the direct result of the parent’s conduct, including acts, omissions, or failures to act.

The evidence was factually sufficient to support the endangering-conduct finding under subsection (1)(E).

in the Interest of M.P., a Child · filed 2014-08-07(1)(E)

Therefore, we conclude that the evidence is factually sufficient to support the trial court’s endangerment finding as to Father’s conduct under section 161.001(1)(E), and we overrule Father’s third issue.

Section 161.001(1)(D) and (E) do not themselves require a course of conduct to establish endangerment.

in the Interest of D.A., a Child · filed 2014-07-31(1)(D), (E)

The “course of conduct” language that Father references is thus not found in the statutory grounds for termination listed in section 161.001(1)(D) or (E).

Section 161.001(1)(E) permits termination when a parent’s drug use and criminal activity endanger a child by subjecting the child to uncertainty and instability.

in the Interest of A.O., a Child · filed 2014-08-14(1)(E)

Reviewing the record in the light most favorable to the finding and judgment, we conclude that because the factfinder could have reasonably formed a firm belief or conviction that Mother’s drug use and criminal activities subjected A.O. to a life of uncertainty and instability that would endanger his physical and emotional well-being, we overrule this portion of Mother’s second issue with regard to subsection (E).

The evidence supported the finding under subsection (1)(E).

In the Interest of K.S., a Child · filed 2014-08-21(1)(E)

After reviewing the entire record and considering the disputed evidence, we hold that a fact finder could reasonably have formed a firm belief or conviction about the truth of the Department‟s allegations under Section 161.001(1)(E) of the family code.

The evidence legally and factually supported an endangering-conduct finding under subsection (1)(E).

in the Interest of R.R., a Child · filed 2014-10-02(1)(E)

Using the appropriate standards for determining the sufficiency of the evidence, we find that the evidence was legally and factually sufficient to support the jury’s finding pursuant to section 161.001(1)(E).

Section 161.001(1)(E) requires clear and convincing evidence of a deliberate or conscious course of conduct that endangers a child.

in the Interest of Z.H., a Child · filed 2014-10-06(1)(E)

Subsection (E) requires evidence of more than a single act, instead there must be clear and convincing evidence of a deliberate or conscious course of conduct.

Section 161.001(1)(E) permits termination when a parent’s conduct, or the conduct of people with whom the parent knowingly places the child, endangers the child’s physical or emotional well-being.

M. v. v. Texas Department of Family and Protective Services · filed 2014-10-08(1)(E)

Considering the evidence in the light most favorable to the trial court’s findings, a reasonable fact finder could have formed a firm belief or conviction that pursuant to Section 161.001(1)(E), Appellant engaged in conduct or knowingly placed the child with persons who engaged in conduct that endangered the children’s physical or emotional well-being.

Under § 161.001(1)(E), a parent’s conduct both before and after a child’s removal is relevant to whether the parent endangered the child.

R. Z., A/K/A R. L., A/K/A R. G. v. Texas Department of Family and Protective Services · filed 2014-11-07(1)(E)

But evidence of her conduct both before and after the removal is relevant to the endangerment determination under subsection (E).

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

in the Interest of A.A. and A.A., Children · filed 2014-11-07(1)(E)

After reviewing the evidence in both the light most favorable to the findings and in a neutral light, we find that the trial court could have reasonably formed a firm belief or conviction that Scott engaged in a course of conduct, including drug and alcohol abuse and violent behavior against the children’s mother, both of which resulted in incarceration, which had the effect of endangering the children’s physical and emotional well-being.

The evidence was legally and factually sufficient to support termination under subsection (1)(E).

J. S. v. Texas Department of Family and Protective Services · filed 2014-11-07(1)(E)

Having found the evidence is both legally and factually sufficient to support termination based on Section 161.001(1)(E), we will not address the trial court’s findings related to Subsections (D) and (N).

Section 161.001(1)(D) and (E) do not expressly require proof of a “course of conduct” to establish endangerment.

in the Interest of A.N. and J.N., Jr., Children · filed 2014-11-07(1)(D), (E)

With regard to Father’s argument that one positive drug test does not establish a conscious course of conduct, the “course of conduct” language that Father uses is not found in the statutory grounds for termination listed in section 161.001(1)(D) or (E).