Tex. Fam. Code Ann. § 161.001

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

N. A. B. and A. D. J. v. Texas Department of Family and Protective Services · filed 2014-11-26(1)(E)

Viewing the above and other evidence in the light most favorable to the jury’s finding, we conclude that the evidence is legally sufficient to support a finding that A.D.J.’s conduct endangered the physical and emotional well-being of his child.

Subsection (E) requires a voluntary, deliberate, and conscious course of conduct by the parent; a single act or omission is insufficient.

P. A. G. v. Texas Department of Family and Protective Services · filed 2014-12-10(E)

Additionally, 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.

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

in the Interest of A.D. and B.H. · filed 2014-12-11(1)(E)

We, therefore, conclude 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 clear and convincing evidence shows that a parent’s course of conduct endangered the child’s physical or emotional well being.

in the Interest of E. R., a Child · filed 2014-12-11(1)(E)

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

Section 161.001(1)(E) requires clear and convincing evidence that a parent engaged in conduct endangering a child’s physical or emotional well-being.

in the Interest of M.C.C. and S.E.C., Children · filed 2014-12-18(1)(E)

We hold that there was clear and convincing evidence from which the trial court could reasonably have formed a firm belief that the mother engaged in conduct that endangered the children’s physical or emotional well-being. See FAM. § 161.001(1)(E).

Sexual abuse of a child is conduct that endangers the child’s physical or emotional well being under subsection (1)(E).

A. E. and J. L. v. Texas Department of Family and Protective Services · filed 2014-12-23(1)(E)

Therefore, Garza’s testimony alone is sufficient to support the trial court’s conclusion that John engaged in conduct that endangered Maria’s and Jessica’s physical and emotional well being.

One statutory ground plus a best-interest finding supports termination, and the evidence established subsection (1)(E) here.

in the Interest of Z.M., W.M., and L.M., Children · filed 2015-01-23(1)(E)

Only one predicate finding under Section 161.001(1) is necessary to support a judgment of termination when there is also a finding that termination is in the child’s best interest. ... We conclude that sufficient evidence supported the finding under ground E.

Section 161.001(1)(E) requires clear and convincing evidence of a parental course of conduct that endangers a child’s physical or emotional well-being.

in the Interest of R.R v. II, a Child · filed 2015-02-10(1)(E)

We hold that the evidence is legally and factually sufficient to support the finding under Section 161.001(1)(E) because the mother engaged in a course of conduct that endangered the child’s 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 M.D. and B.D., Children · filed 2015-02-23(1)(E)

From all of these facts and the remaining evidence in the record, we conclude that the trial court could have formed a firm belief or conviction that Mother had engaged in conduct that endangered the children’s physical or emotional well-being. 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; repeated drug abuse and related criminal conduct can establish that ground.

in the Interest of C.A.J., a Child · filed 2015-02-27(1)(E)

Based on all of the evidence introduced in this case, we conclude that the trial court could readily have reached the necessary firm conviction or belief that Larry engaged in a course of conduct which endangered C.A.J.’s physical or emotional well-being.

Subsection (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.M. and A.M, Children · filed 2015-03-18(1)(E)

Accordingly, we find the evidence was legally and factually sufficient to support the subsection (E) endangerment finding with respect to the termination of appellant’s parental rights to her two children.

Section 161.001(1)(E) supplies a ground for 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 R.N.T.N., a Child · filed 2015-03-26(1)(E)

There was clear and convincing evidence from which the trial court could reasonably have formed a firm belief that the mother engaged in conduct or knowingly placed the child with persons who engaged in conduct that endangered the physical or emotional well-being of the child.

The court upheld the termination ground in subsection (1)(E) and did not reach the alternative ground in subsection (1)(O).

in the Interest of T.L.R and T.J.R., Children · filed 2015-04-02(1)(E)

Having determined that the evidence is sufficient to support the trial court’s finding on the statutory ground in subsection E, we need not consider whether the evidence would support subsection O, the other predicate ground for termination challenged in the Mother’s second issue.

The court upheld termination under subsections (1)(D) or (1)(E) after reviewing the evidence.

in the Interest of T.R.L. and C.J.L., Children · filed 2015-03-05(1)(D), (1)(E)

Considering all the evidence in the light most favorable to the trial court’s findings, we hold that a reasonable factfinder could have formed a firm belief or conviction that K.L.’s and J.R.L.’s parental rights should be terminated under subsections 161.001(1)(D) or 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 K.M. A/K/A K v. a Child · filed 2015-03-23(1)(E)

We conclude that the evidence was legally and factually sufficient to allow the trial court as fact-finder to determine that Mother endangered K.M. based on the repeated domestic-violence incidents at which K.M. was present and, in one instance, unsupervised; Mother’s drug abuse; and Mother’s arrests for domestic violence and public intoxication in K.M.’s presence.

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

in the Interest of T.M., a Child · filed 2015-04-16(1)(E)

We hold that the evidence supporting termination under Family Code section 161.001(1)(E) is legally and factually sufficient.

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

N. D. v. Texas Department of Family and Protective Services · filed 2015-04-20(1)(E)

Thus, we conclude that the evidence was legally and factually sufficient to support the trial court’s finding under section 161.001(1)(E), overrule N.D.’s second issue as to finding of fact number 7, and decline to address her first issue and the remainder of her second issue.

Subsection (1)(E) permits termination when a parent’s repeated drug use and criminal conduct, resulting in prolonged incarceration, endangers a child’s physical or emotional well-being.

in the Interest of G.C.D., a Child · filed 2015-04-29(1)(E)

Based on the evidence of Father’s pattern of drug use and other criminal behavior, resulting in multiple incarcerations spanning more than eighteen years, we hold the trial court could have reasonably formed a firm belief or conviction that Father engaged in conduct that endangered G.C.D.’s physical or emotional well-being.

Section 161.001(1)(E) requires clear and convincing evidence of a parental course of conduct that endangers a child’s physical or emotional well-being.

in the Interest of D.T.M., J.B.M. and R.A.M., Children · filed 2015-04-30(1)(E)

We hold that there was clear and convincing evidence from which the trial court could reasonably have formed a firm belief that the mother engaged in a course of conduct that endangered the children’s physical or emotional well-being.

The court upheld a finding that the father’s conduct endangered the child under subsection (1)(E).

T. M. and J. R. v. Texas Department of Family and Protective Services · filed 2015-05-21(1)(E)

In light of the entire record, we determine that the jury could have reasonably formed a firm belief that Father “engaged in conduct . . . which endangers the physical or emotional well-being of the child.” Tex. Fam. Code § 161.001(1)(E).

Section 161.001(1)(E) allows a finding of endangerment based on a parent’s course of conduct toward other children, even without proof that the child at issue suffered the same harm.

in the Interest of J.W.C., a Child · filed 2015-05-27(1)(E)

It was not necessary to show J.W.C.’s nutritional needs had not been met. ... Accordingly, we conclude the evidence was legally and factually sufficient to support the termination finding for Mother and Father under subsection (E).

The court upheld termination under subsection (1)(E) after finding evidence sufficient to support the statutory ground.

in the Interest of J.J.G and D.J.T-B., Children · filed 2015-06-04(1)(E)

Reviewing the evidence under the appropriate standards, we conclude that the trial court could have formed a firm belief or conviction that termination of the Mother’s parental rights is warranted under section 161.001(1)(E).

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

L. C. v. Texas Department of Family and Protective Services · filed 2015-06-10(1)(E)

Viewing the above and other evidence in the light most favorable to the jury’s finding, we conclude that the evidence is legally sufficient to support a finding that L.C.’s conduct endangered the physical and emotional well-being of her child.

The court upheld a subsection (1)(E) finding based on the mother’s drug problems, violent relationship, and repeated poor judgment.

in the Interest of D. v. a Child · filed 2015-06-03(1)(E)

Consequently, we will address Mother’s point of error related to subsection E. ... In addition to her drug problems and her inability to extract herself from a violent relationship, she has repeatedly demonstrated poor judgment, poor parenting skills, and an inability to give priority to her son. Because the evidence is both legally and factually sufficient to support the finding, we overrule Issue Two and do not consider Issues One, Three, Four, and Five.

The court upheld a predicate termination ground under subsection (1)(E) and did not reach the other challenges.

in the Interest of R.M., B.M., and N.M., Children · filed 2015-06-04(1)(E)

Because we find that evidence is legally and factually sufficient to support the trial court’s finding of a predicate act pursuant to Section 161.001(1) (E), we need not reach the first and second issues.

The court upheld termination under subsection (1)(E) after finding the evidence sufficient.

in the Interest of L.E.R., a Child · filed 2015-06-25(1)(E)

Reviewing the evidence under the appropriate standards, we conclude that the trial court could have formed a firm belief or conviction that termination of the parents’ rights is warranted under section 161.001(1)(E).

Subsection (1)(E) allows endangerment to be shown through knowing placement with an abusive caregiver or a continuing course of conduct involving drug use and domestic violence.

in the Interest of J.J.G., a Child · filed 2015-07-03(1)(E)

When viewed in the light most favorable to a finding of endangerment as well as in light of the entire record, we find a reasonable factfinder could have formed a firm belief or conviction that the mother knowingly placed B.J.H. and J.J.G. in an endangering condition when she left them in the care of the father after J.J.G.’s assault at the father’s hands; engaged in an endangering course of conduct by using illegal drugs, both before the children’s removal and during the pendency of the termination suit; and engaged in a continuing course of endangering conduct through participation in an ongoing abusive relationship with the father.

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 C.D.A. and M.R.A., Children · filed 2015-07-15(1)(E)

This evidence permitted the fact finder to reasonably form a firm belief or conviction that Carla engaged in conduct or knowingly placed her children with persons who engaged in conduct that endangered the physical or emotional well-being of those children.

The court upheld a subsection (b)(1)(E) finding and a best-interest finding under subsection (b)(2).

in the Interest of T.G., L.G., and M.G., Children · filed 2015-07-17(b)(1)(E)

Because legally and factually sufficient evidence supported the trial court’s finding that Tamara violated section 161.001(b)(1)(E) and factually sufficient evidence supported the trial court’s finding that termination of Tamara’s parental rights was in the children’s best interest under section 161.001(b)(2), we overrule Tamara’s issues.

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

in the Interest of R.H., M.D.J. and M.K. Children v. Department of Family and Protective Services · filed 2015-07-28(1)(E)

Therefore, viewing all of the evidence in this case in a light most favorable to the trial court’s findings, we hold that a reasonable factfinder could form a firm belief or conviction that D.K. engaged in conduct or knowingly placed her children with persons who engaged in conduct that endangered the children’s physical or emotional well-being.

The court upheld a subsection (1)(E) finding after determining the evidence was legally and factually sufficient.

in the Interest of Z.J.J. and Z.J. · filed 2015-07-30(1)(E)

We conclude that the evidence is legally and factually sufficient to support the trial court’s finding under section 161.001(1)(E).

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

in the Interest of J.S., a Child · filed 2015-08-12(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to support termination of C.S.’s and S.A.’s parental rights 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 the child’s physical or emotional well-being.

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

These seemingly innocuous events, she contends, do not amount to clear and convincing evidence supporting termination under Section 161.001(1)(E). We disagree and hold that legally and factually sufficient evidence supports the finding that Julie knowingly engaged in conduct that endangered S.S.’s physical or emotional well-being.

Subsection (1)(E) permits termination when clear and convincing evidence shows a parent engaged in a voluntary, deliberate, and conscious course of conduct that endangered a child’s well-being.

in the Interest of A.L.P., E.R.C., and J.C.C., Children · filed 2015-08-21(1)(E)

Consequently, we hold that the evidence is legally and factually sufficient to support the finding under Section 161.001(1)(E) because the mother engaged in a voluntary, deliberate, and conscious course of conduct that endangered the children’s well-being.

The court upheld a finding under the endangering-conduct ground in subsection (1)(E).

in the Interest of K.M.-J. AKA K.M-J and D.A.R.-J. v. Department of Family and Protective Services · filed 2015-09-08(1)(E)

Thus, we conclude that the evidence is legally and factually sufficient to support the trial court’s finding under section 161.001(1)(E).

Chronic drug use can establish the endangering course of conduct required for termination under subsection (1)(E).

in the Interest of S.H., a Child · filed 2015-09-16(1)(E)

From the evidence presented, the trial court reasonably could have reached a firm conviction W.W. had pursued a course of conduct, through her chronic drug use, that endangered S.H.’s physical and emotional well-being.

Section 161.001(1)(E) does not require proof that a parent knowingly committed her own endangering acts.

in the Interest of J.N.G., a Child · filed 2015-09-24(1)(E)

Scienter, however, is not required for appellant’s own acts under § 161.001(b)(E); scienter is required only under subsection (D) when a parent places her child with others who engage in endangering acts.

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

in the Interest of J.S. · filed 2015-10-01(1)(E)

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

Section 161.001(1)(E) requires a course of endangering conduct to terminate parental rights.

in the Interest of D.C. and E.C., Children · filed 2015-10-22(1)(E)

We also believe that the evidence establishes a course of endangering conduct that is required under subsection (E).

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

in the Interest of O.D.H., a Child · filed 2015-11-10(1)(E)

Reviewing all the evidence in the light most favorable to the termination finding under subsection E, we conclude a reasonable factfinder could have formed a firm belief or conviction as to the truth of the finding that Mother engaged in endangering conduct.

Section 161.001(b)(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.F., J.L., and J.N., Children · filed 2015-11-19(b)(1)(E)

Based on all the evidence in this case, a rational trier of fact could have reached a firm conviction that DeDe engaged in conduct that endangered the physical and/or emotional well-being of her children. Therefore, we find the evidence legally and factually sufficient to support the trial court’s finding under subsection (E).

Section 161.001(b)(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.A. and S.G., Children · filed 2015-12-10(b)(1)(E)

Based on these facts and the remaining evidence in the record, under the authority cited above, we conclude that the evidence is legally sufficient to support the trial court’s finding that Mother engaged in conduct that endangered the children’s physical or emotional well-being.

Section 161.001(b)(1)(E) permits termination when a parent’s deliberate course of drug use and criminal conduct endangers children by exposing them to impaired judgment and an unstable home.

In the Interest of M.C. · filed 2016-01-11(b)(1)(E)

This conscious and deliberate course of conduct exposed the children to a parent whose impaired judgment exposed them to loss or injury and to the loss of a stable home environment as a result of the possibility of repeated incarcerations. We find that this evidence is legally and factually sufficient to support the trial court’s finding under subsection E, and we overrule this point of error.

Section 161.001(b)(1)(E) permits termination when a parent’s continuing course of conduct endangers a child’s physical or emotional well-being; the conduct need not occur in the child’s presence or cause actual harm.

in the Interest of S. R. H., a Minor Child · filed 2016-02-04(b)(1)(E)

Furthermore, Subsection E does not require that the parent’s conduct be directed at the child or cause actual harm; rather, it is sufficient if the parent’s course of conduct endangers the well-being of the child.

A parent’s continued narcotics use and decision to live with a known drug dealer while caring for children can support an endangerment finding under subsection (b)(1)(E).

in the Interest of B.J., Jr., B. J., D. L., and D. L.. Children · filed 2016-04-07(b)(1)(E)

The trial court could have reasonably found that T.T.’s continued narcotics use, long history of involvement with individuals who also used narcotics, and decision to be in a relationship with, and live with, the father of D.L. and D.B.L., a known “drug dealer,” while she cared for the four children, qualified as a continuing course of conduct that subjected them to a life of uncertainty and instability, endangering their physical and emotional well-being.

Section 161.001(b)(1)(E) allows termination when a parent's course of conduct endangers a child's physical or emotional well-being; sustained neglect of medical needs can satisfy that ground.

in the Interest of K.S., a Child · filed 2016-04-21(b)(1)(E)

The evidence is legally and factually sufficient to support the jury’s finding under section 161.001(b)(1)(E).

Subsection (b)(1)(E) permits termination based on a parent’s course of conduct that endangers a child, even while the child is in the Department’s custody.

in the Interest of K.P. Child v. Department of Family and Protective Services · filed 2016-05-26(b)(1)(E)

Given the evidence of (1) Mother’s course of conduct of drug use while still maintaining custody of KY, (2) Mother’s long-term lack of residence or stable living arrangements, (3) Mother’s sporadic and inconsistent visitation of KP, (4) Mother’s untreated mental illnesses, and (3) Mother’s testimony that she and KP would live with TR, who also failed drug tests shortly before trial, the trial court’s endangerment finding under section 161.001(1)(b)(E) is supported by legally and factually sufficiency evidence.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being, even if the conduct occurs outside the child’s presence.

in the Interest of S.L.N.G., a Child · filed 2016-05-12(b)(1)(E)

Using the appropriate standards, we find that the evidence was legally and factually sufficient to support the trial court’s findings of fact relating to the determination that Dillon had engaged in conduct that endangered the child's physical or emotional well-being. Because we have found the evidence legally and factually sufficient as to one predicate act pursuant to section 161.001(b)(1), we overrule issue one.

Section 161.001(b)(1)(E) allows a finding of endangerment based on a parent’s course of conduct even when the child is outside the parent’s custody.

In re K.P. · filed 2016-05-26(b)(1)(E)

While it is true that it has been a long time since KP has resided with Mother, the cases interpreting section 161.001(l)(b)(E) demonstrate that evidence of a parent’s course of conduct, even when the parent is not in possession of their child, can support a finding of endangerment.

Section 161.001(b)(1)(E) permits a finding of endangering conduct based on a parent’s course of violence or abuse toward the other parent, even when the child is not present.

in the Interest of A.S., a Child · filed 2016-06-16(b)(1)(E)

Violent or abusive conduct directed at the other parent or other people, even if it is not committed in the child’s presence, may also be sufficient to show a course of conduct under section 161.001(b)(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 A.W.G. Jr., a Child · filed 2016-07-07(1)(E)

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 Father’s parental rights was justified under section 161.001(1)(E) of the Family Code.

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

in the Interest of A. H., a Child · filed 2016-07-12(b)(1)(E)

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

Section 161.001(1)(E) requires a voluntary, deliberate, conscious course of parental conduct that endangers a child’s physical or emotional well-being.

in the Interest of R.S.S, J.D.S., I.D.S. & K.E.S., Children · filed 2016-07-14(1)(E)

Termination under subsection 161.001(1)(E) must be based on more than a single act or omission—the evidence must demonstrate a voluntary, deliberate, and conscious course of conduct by the parent. ... We hold that the evidence supporting termination under Family Code section 161.001(1)(E) is factually sufficient.

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

in the Interest of A.R., J.S., A.F., A.A., and A.A., Children · filed 2016-09-22(b)(1)(E)

The evidence is legally and factually sufficient to support the finding under Section 161.001(b)(1)(E) because the father engaged in a voluntary, deliberate, and conscious course of conduct that endangered the children’s well-being.

Section 161.001(b)(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 A.M.A., a Child · filed 2016-09-27(b)(1)(E)

We therefore overrule appellant’s first issue that the evidence was not factually sufficient to support the trial court’s judgment that G.A. had engaged in endangering conduct under section 161.001(b)(1)(E).

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

in the Interest of A. S., a Child · filed 2016-09-30(b)(1)(E)

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

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being; continued drug use can support a finding of endangerment.

in the Interest of B.M.C. and C.M.C., Children · filed 2016-10-04(b)(1)(E)

Mother’s failure to remain drug-free while under DFPS supervision supports the trial court’s finding of endangering conduct.

Section 161.001(b)(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. L. M., K. A. S., B. B. S., and A. L. S., Minor Children · filed 2016-11-15(b)(1)(E)

Accordingly, the evidence is both legally and factually sufficient to support the termination findings under Family Code Section 161.001(b)(1)(E).

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

in the Interest of O.D.M.S. and N.S., Children · filed 2016-12-08(b)(1)(E)

Based on this record and viewing the evidence using the referenced standards for the legal and factual sufficiency of the evidence, we find that the evidence was sufficient for the trial court to have found by clear and convincing evidence that Angelica engaged in conduct that endangered the children's physical or emotional well-being.

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

in the Interest of K. R. G. and K. W. G, Children · filed 2016-12-15(b)(1)(E)

Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that K.G. engaged, or knowingly placed K.R.G. and K.W.G. with persons who engaged, in conduct that endangered their physical and emotional well-being. See TEX. FAM. CODE ANN. § 161.001(b)(1)(E).

Subsection (b)(1)(E) permits termination when clear and convincing evidence shows a voluntary, deliberate, and conscious course of parental conduct that endangers a child’s physical or emotional well-being.

in the Interest of S.D.and G.D., Minor Children · filed 2017-01-05(b)(1)(E)

We conclude that the above evidence is legally and factually sufficient for a factfinder to reasonably form a firm belief or conviction that Mother engaged not just in a single act or omission that endangered the children’s physical or emotional well-being, but in a voluntary, deliberate, and conscious course of conduct that endangered the physical or emotional well-being of the children.

Subsection (b)(1)(E) permits termination when a parent's conduct endangers the child's physical or emotional well-being, including conduct before or after the child's removal.

In the Interest of A.L.H. · filed 2017-01-10(b)(1)(E)

Our review is of the evidence introduced at the trial of the Consolidated Cases that Father, before or after Adam’s removal, “engaged in conduct or knowingly placed the child with persons who engaged in conduct which endangers the physical or emotional well-being of the child.” Tex. Fam. Code Ann. § 161.001(b)(1)(E). As discussed, the evidence is sufficient to support a finding of endangerment under subsection E.

Section 161.001(b)(1)(E) permits termination for a parent's endangering course of conduct; incarceration and deportation alone are insufficient, but may be considered with a parent's prolonged absence and lack of contact.

In re R.A.G. · filed 2017-01-11(b)(1)(E)

While incarceration and deportation are not sufficient, standing alone, to support a finding under Section 161.001(b)(1)(E), these facts are part of Appellant's overall course of conduct. We conclude that the evidence is legally and factually sufficient to establish a firm conviction or belief in the mind of the trier of fact that Appellant engaged in conduct that endangered R.A.G.'s physical or emotional well-being under Section 161.001(b)(1)(E).

Subsection (b)(1)(E) permits an endangerment finding based on a parent’s pattern of domestic violence, including conduct before the child’s birth.

in the Interest of J. H., V, a Child · filed 2017-01-12(b)(1)(E)

This evidence was legally and factually sufficient to support the trial court’s finding by clear and convincing evidence, under part (E) of subsection 161.001(b)(1), that appellant engaged in conduct which endangered J.H. V’s physical or emotional well-being.

Section 161.001(b)(1)(E) requires a voluntary, deliberate course of conduct that endangers a child’s physical or emotional well-being; repeated drug use and criminal conduct may support that finding.

in the Interest of L.T.B. and L.M.A., Children · filed 2016-11-03(b)(1)(E)

Accordingly, we conclude the evidence is factually sufficient to support the section 161.001(b)(1)(E) finding.

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 drug use or exposure to domestic violence.

R. R. v. Texas Department of Family and Protective Services · filed 2016-11-03(1)(E)

We will focus our analysis on the ground stated in section 161.001(1)(E), which provides that parental rights may be terminated if the parent “engaged in conduct or knowingly placed the child with persons who engaged in conduct which endangers the physical or emotional well-being of the child.” ... Because we conclude that the evidence is legally and factually sufficient to support the district court’s endangerment finding, we need not consider the sufficiency of the evidence supporting the other alleged statutory grounds for termination.

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows that a parent’s conduct endangers a child’s physical or emotional well-being; a history of violent crime can support that finding.

in the Interest of J.R. and M.D.N.S.T., Children · filed 2016-12-13(b)(1)(E)

Father’s past violent, criminal history provides legally and factually sufficient evidence to support a firm belief or conviction that Father engaged in conduct that endangers Mary’s physical or emotional well-being, supporting termination under Subsection (E).

Section 161.001(b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being, and continuous sexual abuse satisfies that ground.

in the Interest of M.J.P., a Child · filed 2017-02-17(b)(1)(E)

We conclude the evidence is both legally and factually sufficient to support the trial court’s finding that Father engaged in conduct which endangers M.J.P.’s physical or emotional well-being.

Section 161.001(b)(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 Q. W., III, a Child · filed 2017-03-31(b)(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to support termination of L.G.’s parental rights under section 161.001(b)(1)(E).

Section 161.001(1)(E) allows termination based on conduct that endangers a child’s physical or emotional well-being; drug use and criminal conduct can support that finding.

in the Interest of G.G.C. AKA G.C.G., E.G.C., R.D.G.C. AKA R.G.C., K.S.G.M. AKA K.G.M., K.M.G.M AKA K.G.M. and K.E.G.M. · filed 2017-05-02(1)(E)

We hold that legally and factually sufficient evidence supported the trial court’s determination that the mother endangered the wellbeing of the children.

Section 161.001(b)(1)(E) permits termination when a parent engages in conduct that endangers a child or knowingly places the child with someone whose conduct does so.

In the Interest of R.S.-T. · filed 2017-05-17(b)(1)(E)

Based on a review of the direct and circumstantial evidence contained in the record, we conclude the trial court could have formed a firm belief or conviction that Ralph engaged in conduct or knowingly placed R.S.-T. with Carla, an individual engaging in conduct which endangered R.S.-T.’s physical or emotional well-being.

A parent’s domestic violence and criminal history can support a finding of endangerment under subsection (E).

A. W. and R. R. v. Texas Department of Family and Protective Services · filed 2017-07-14(b)(1)(E)

Therefore, we conclude that the evidence is factually sufficient to support the termination of R.R.’s parental rights under subsection (E).

Section 161.001(b)(1)(E) makes a parent's conduct a ground for termination when it directly endangers a child's physical or emotional well-being.

in the Interest of T.G., a Child · filed 2017-08-08(b)(1)(E)

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

Termination under subsection (1)(E) requires evidence of a voluntary, deliberate, and conscious course of conduct by the parent, rather than a single act or omission.

In the Interest of E.R.W. · filed 2017-09-05(1)(E)

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

Section 161.001(b)(1)(E) allows termination based on conduct that endangers a child’s physical or emotional well-being; continued illegal drug use can support an endangerment finding.

in the Interest of K.B., a Child · filed 2017-09-15(b)(1)(E)

We conclude there was sufficient evidence from which the trial court could have formed a firm belief or conviction that Father committed conduct that endangered K.B.’s physical or emotional well-being, in violation of section 161.001(b)(1)(E) of the family code.

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

in the Interest of S.L.W., a Child · filed 2017-09-20(b)(1)(E)

“However, termination under this ground ‘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(b)(1)(E) permits termination when clear and convincing evidence shows that a parent engaged in conduct, or knowingly placed a child with someone who engaged in conduct, that endangered the child’s physical or emotional well-being.

in the Interest of C. P., a Child · filed 2017-09-29(b)(1)(E)

The record contains clear and convincing evidence that Appellant had engaged in conduct or knowingly placed the child with persons who engaged in conduct that endangered the child’s physical or emotional well-being—as required to support a finding under Section 161.001(b)(1)(E).

Section 161.001(b)(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.L.B. · filed 2017-11-01(b)(1)(E)

Viewing all the evidence in the light most favorable to the trial court’s judgment, we conclude a reasonable trier of fact could have formed a firm belief or conviction Mother engaged in conduct which endangered the physical or emotional well-being of the children. Thus, the evidence is legally sufficient to support this finding. Based upon the same evidence and conclusions, the evidence is also factually sufficient to support the trial court’s termination finding under Section 161.001(b)(1)(E).

Section 161.001(b)(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.N.T.S. v. Department of Family and Protective Services · filed 2017-11-16(b)(1)(E)

Accordingly, we conclude the evidence is legally and factually sufficient to support the section 161.001(b)(1)(E) finding as to Ana, Bonnie, Andrea, and Julian.

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

in the Interest of A.F.G., B.N.G., A.M.G., and J.L.G. Jr., Children · filed 2017-11-16(b)(1)(E)

Accordingly, we conclude the evidence is legally and factually sufficient to support the section 161.001(b)(1)(E) finding as to Ana, Bonnie, Andrea, and Julian.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child, including by exposing the child to ongoing domestic violence and illegal drugs.

in the Interest of K.D., C.D., and C.F., III, Children · filed 2017-11-17(b)(1)(E)

Here, the record is replete with evidence of long-standing domestic violence in the family home as well as Mother’s illegal drug use, C.F., Jr.’s, illegal drug use, and at least two of the children’s exposure to measurable amounts of illegal drugs. We, therefore, must affirm the trial court’s order terminating Mother’s parental rights to K.D., C.D., and C.F., III, pursuant to Section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) allows a court to consider a parent's failure to complete significant service plan requirements when deciding whether the parent engaged in endangering conduct.

In re P.H. · filed 2017-11-28(b)(1)(E)

The trial court could have considered Laura's failure to complete significant requirements of the service plan as part of the analysis under Subsection 161.001(b)(1)(E). ... Based on this evidence, the trial court could have formed a firm conviction or belief that Laura engaged in conduct that endangered Penny's emotional and physical well-being. The same evidence is factually sufficient to support the trial court's affirmative finding.

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

in the Interest of P. M. B. and M. A. B., Children · filed 2017-12-19(b)(1)(E)

Accordingly, we hold that the evidence was legally and factually sufficient to support the Subsection E endangerment finding. See TEX. FAM. CODE ANN. § 161.001(b)(1)(E).

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

in the Interest of M.S., a Child · filed 2018-01-05(b)(1)(E)

Additionally, 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(b)(1)(E) allows a court to consider a parent’s misconduct after a child’s removal when deciding whether the parent engaged in an endangering course of conduct.

in the Interest of R.B., a Child · filed 2017-10-19(b)(1)(E)

So, evidence of misconduct after removal of the child should be considered in assessing whether the requisites of (E) have been met.

Section 161.001(b)(1)(E) does not require direct evidence to support a finding of endangering conduct.

In re Interest of R.H.W. · filed 2018-01-09(b)(1)(E)

But, even if the record did not contain direct evidence, as Father alleges, direct evidence is not necessarily required to support the predicate finding under section 161.001(E).

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

in the Interest of C. R. and C. R., Minor Children · filed 2018-03-06(b)(1)(E)

Accordingly, we hold that legally and factually sufficient evidence supports the trial court’s finding under section 161.001(b)(1)(E).

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

in the Interest of B.W. and C. W., Children · filed 2018-03-07(b)(1)(E)

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

Subsection (b)(1)(E) permits termination when a parent’s drug use, continued relationship with a violent partner, and instability establish an endangering course of conduct.

in the Interest of O.T., a Child · filed 2018-03-09(b)(1)(E)

While it is true that there was evidence that Mara loved Omar and was a good mother, the evidence also established that Mara’s drug use, continued relationship with Jim, and lack of stability established an endangering course of conduct.

Section 161.001(b)(1)(E) permits termination when sufficient evidence shows that a parent engaged in conduct that endangered a child's physical or emotional well-being or knowingly placed the child with someone who did.

In re Interest of E.J.Z. · filed 2018-04-04(b)(1)(E)

Because our conclusion that sufficient evidence supported the jury's decision to terminate Father's parental rights under Section 161.001(b)(1)(E) is dispositive, we need not address Father's complaint of alleged jury charge error.

Under subsection (b)(1)(E), endangering conduct need not be directed at the child, and the child need not suffer an injury.

in the Interest of A.M. and A.M., Children · filed 2018-04-05(b)(1)(E)

We note that, under subsection (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(b)(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being.

In re Interest of K-A.B.M. · filed 2018-04-25(b)(1)(E)

Having reviewed the evidence in the appropriate light under each standard of review, we conclude that it is both legally and factually sufficient for a reasonable trier of fact to form a firm belief or conviction that Mother engaged in conduct which exposed the children to a life of uncertainty and instability and thereby endangered the physical or emotional well-being of the children.

A pattern of medical neglect, failure to provide basic needs, and persistent illegal drug use can establish endangering conduct under subsection (b)(1)(E).

in the Interest of J. v. B., J. M. B., S. A. B., C. C. B. and T. J., Children v. Department of Family and Protective Ser · filed 2018-06-07(b)(1)(E)

Considering the evidence in the light most favorable to the trial court’s finding under section 161.001(1)(b)(E), we conclude that a reasonable trier of fact could have formed a firm belief or conviction that J.V.J.’s conduct endangered her children’s physical or mental well-being.

Section 161.001(b)(1)(E) permits termination when a parent's conduct endangers a child's physical or emotional well-being, including by posing physical risks or creating instability and uncertainty.

L. D.-C. v. Texas Department of Family and Protective Services · filed 2018-06-14(b)(1)(E)

Nevertheless, considering all the evidence in the light most favorable to the trial court’s finding, we determine that the trial court could have reasonably formed a firm belief or conviction that Mother endangered the children by posing physical risks to them and by generating instability and uncertainty in their lives. We therefore conclude that legally sufficient evidence supports the trial court’s finding under subsection (E).

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child, including continued drug use and failure to protect an unborn child from known prenatal drug use.

in the Interest of H.M.J., a Child · filed 2018-06-19(b)(1)(E)

After reviewing all of 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 Jacob knowingly engaged in conduct which endangered Hanna’s physical or emotional well-being. Therefore, we find the evidence legally and factually sufficient to support the termination of Jacob’s parental rights to Hanna.

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

in the Interest of A.R.C. and S.A.C., Children · filed 2018-06-21(b)(1)(E)

The evidence supports the trial court’s finding that the parents endangered the children’s physical or emotional well-being. Consequently, we hold that the evidence is legally and factually sufficient to support the trial court’s findings under Section 161.001(b)(1)(E).

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

in the Interest of J. I. T. and J. A. T. v. Department of Family and Protective Services · filed 2018-06-27(b)(1)(E)

We further hold that, viewed in light of the entire record, any disputed evidence could have been reconciled in favor of a finding of endangerment under Section 161.001(b)(1)(E) or was not so significant that the factfinder could not reasonably have formed a firm belief or conviction of endangerment.

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

in the Interest of J.G. and T.S.A.G., Children · filed 2018-08-01(b)(1)(E)

Considering all of the evidence, we find that the trial court could have reasonably formed a firm belief or conviction that Jake engaged in a course of conduct which endangered the emotional or physical well-being of his children.

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

in the Interest of K.M., B.H., D.H. and J.H.H., Children · filed 2018-08-09(b)(1)(E)

More specifically, we conclude that the trial court was presented with clear and convincing evidence of ground (E) endangerment by both parents.

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

in the Interest of A. R. O., a Child · filed 2018-08-14(b)(1)(E)

Termination under this subsection 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. ... After reviewing the entire record, we conclude that the evidence is both legally and factually sufficient to establish a firm conviction in the mind of the trial court that Appellant engaged in conduct that endangered the physical or emotional well-being of the child.

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

in the Interest of F.H., a Child · filed 2018-08-21(b)(1)(E)

Accordingly, we conclude the evidence is legally and factually sufficient to support the section 161.001(b)(1)(E) finding.

Section 161.001(b)(1)(E) permits termination for endangering conduct, and a parent’s recent improvement does not necessarily outweigh a long history of drug use and relapse.

in the Interest of G.A., Child · filed 2018-10-23(b)(1)(E)

Accordingly, we hold that the evidence was factually sufficient to support the trial court’s finding under Subsection (E).

Subsection (b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being, provided termination is also in the child’s best interest.

in the Interest of J.T.T.J., K.A.T. and R.D.R.T., Minor Children · filed 2018-11-01(b)(1)(E)

Mother’s actions that allowed a registered sex offender to have daily access to her children without her supervision was sufficient evidence to support a finding based on section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being, even without proof of physical injury.

in the Interest of C.A.D. · filed 2018-10-18(b)(1)(E)

Having carefully considered all the evidence admitted in the trial, we conclude the jury could have reasonably formed a firm belief or conviction that Father engaged in conduct that endangered Claire’s physical or emotional well-being.

Section 161.001(b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being, including by exposing the child to abuse.

in the Interest of R.A. and D.A., Children · filed 2018-11-08(b)(1)(E)

The trial court could likewise have reasonably formed a firm belief or conviction that Father had engaged in conduct that endangered the children’s physical or emotional well-being when he allowed them to witness his abuse of their mother and allowed one of his friends to abuse R.A.

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

in the Interest of C.W., D.T., J.T., and A.T., Children · filed 2018-11-13(b)(1)(E)

Considered in the light most favorable to the trial court’s finding, the evidence is legally and factually sufficient to support the trial court’s determination that termination of Mother’s parental rights was justified under section 161.001(b)(1)(E) of the Family Code.

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

in the Interest of C. J. W., Child v. Department of Family and Protective Services · filed 2018-11-13(b)(1)(E)

After reviewing all the evidence in the light most favorable to the trial court’s finding, including evidence of Father’s pattern of committing violent felony offenses with a firearm and the fact that Father has been incarcerated for most of his adult life as a result of two such offenses, we conclude that a reasonable factfinder could have formed a firm belief or conviction that Father engaged in a course of conduct endangering to Charlie under section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) allows termination when a parent’s course of conduct endangers a child’s physical or emotional well-being; drug use and criminal activity can establish that ground.

in the Interest of R.L.L. III, Children · filed 2018-11-21(b)(1)(E)

Viewing the evidence in the manner required by each standard of review, we conclude that it is both legally and factually sufficient for a reasonable trier of fact to form a firm belief or conviction that Mother engaged in a course of conduct that endangered the physical or emotional well-being of the children.

Section 161.001(b)(1)(E) permits termination for a parent’s endangering course of conduct, including drug use before birth and continued drug use afterward, even when the parent never had physical custody of the child.

in the Interest of S.S. and S.S., Children · filed 2018-11-28(b)(1)(E)

Thus, based on the evidence produced at trial, we conclude that a rational jury could have reasonably formed a firm conviction or belief that K.S. engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered their physical and emotional well-beings.

Section 161.001(b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being; domestic violence, improper medication use, and neglect may establish that ground.

in the Interest of A. K. T. v. Department of Family and Protective Services · filed 2018-12-06(b)(1)(E)

Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that mother engaged, or knowingly placed A.K.T. with persons who engaged, in conduct that endangered her physical and emotional well-being.

Section 161.001(b)(1)(E) permits termination for endangering conduct when a parent fails to obtain medical care for an infant known to have stopped breathing, even if the parent did not know what caused it.

in the Interest of J. D. G AKA J. G., Jr., A. E. G. J. AKA A. G. v. Department of Family and Protective Services · filed 2018-12-11(b)(1)(E)

Thus, a reasonable factfinder could have formed a firm belief that Monica’s failure to obtain a medical evaluation or any medical care for her infant son, whom she had been told had stopped breathing, met the standard for endangering conduct, even if the factfinder accepted that Monica did not know what caused Andres to stop breathing.

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

in the Interest of C.F., a Child · filed 2018-12-13(b)(1)(E)

Thus, clear and convincing evidence supports the trial court’s finding that Appellant endangered the child’s physical or emotional well-being or that she knowingly placed the child with persons who engaged in conduct that endangered the child’s physical or emotional well-being. Consequently, we hold that the evidence is legally and factually sufficient to support the trial court’s finding under Section 161.001(b)(1)(E).

A parent’s violence toward other family members can support termination when it endangers a child’s physical or emotional well-being, even if the conduct was not directed at the child.

in the Interest of K.L.P., and K.M.R.N., A/K/A K.M.N., Children · filed 2018-12-20(b)(1)(E)

Father’s abuse of Kimberly and Mother created an environment which endangered Kandace’s physical and emotional well-being. As stated above, it is not necessary that the parent’s conduct be directed at the child or that the child actually suffer injury in conducting a review under subsection (E).

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

in the Interest of T.M.T., a Child · filed 2018-11-20(b)(1)(E)

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(b)(1)(E) permits a finding of endangerment based on a parent’s voluntary course of conduct, including repeated cocaine use.

in the Interest of D.I.L.-M. AKA D.M., S.K.D.-M., A.M.Q.-M. AKA A.M.B. and A.J.B.-M., Children · filed 2018-12-04(b)(1)(E)

Considered in the light most favorable to the trial court’s finding, the evidence is sufficient to support the trial court’s determination that termination of Mother’s parental rights was justified under section 161.001(b)(1)(E) of the Family Code.

Section 161.001(b)(1)(E) permits termination when a parent’s abandonment and violent criminal conduct form a course of conduct that endangers the child’s physical or emotional well-being.

in the Interest of M.A.F.R., Y.A.V-F., and I.A v. Jr., Children · filed 2018-11-29(b)(1)(E)

Father’s abandonment of Max from birth and Father’s violent sexual crime constitutes a course of conduct that endangered Max’s emotional and physical well-being.

Section 161.001(b)(1)(E) requires a deliberate course of conduct that endangers a child’s physical or emotional well-being; repeated criminal conduct and imprisonment can support that finding.

in the Interest of L.E.H., Jr. and A.C.H., Children · filed 2018-12-31(b)(1)(E)

Termination under section 161.001(b)(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. ... The evidence is legally and factually sufficient to support the findings that Father engaged in conduct that endangered his children’s physical or emotional well-being.

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

in the Interest of J.W.M., Jr., a Child · filed 2019-01-31(b)(1)(E)

Additionally, 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(b)(1)(E) permits termination when a parent’s course of conduct endangers a child, and continued drug use and refusal to submit to testing can support that finding.

in the Interest of J.S., a Child · filed 2019-02-05(b)(1)(E)

Considered in the light most favorable to the trial court’s finding, we conclude that the evidence is legally sufficient to support the trial court’s termination of Mother’s parental rights under section 161.001(b)(1)(E) under these circumstances.

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

in the Interest of E. L. A. III and A. J. E. A., Children v. Department of Family and Protective Services · filed 2019-02-05(b)(1)(E)

Accordingly, we hold that legally and factually sufficient evidence supports the trial court’s finding that Father committed the predicate act set forth under subsection (E).

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

in the Interest of M. L. L., a Child · filed 2019-02-08(b)(1)(E)

We find that the evidence, when considered in the light most favorable to the trial court’s finding, is legally sufficient to support termination of Mother’s parental rights under Section 161.001(b)(1)(E) of the Family Code.

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

in the Interest of A.B v. a Child · filed 2019-02-14(b)(1)(E)

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.

Subsection (b)(1)(E) requires a voluntary, deliberate course of conduct that endangers a child’s physical or emotional well-being; actual injury is unnecessary.

in the Interest of E.F., a Child · filed 2019-02-14(b)(1)(E)

The evidence supports the trial court’s findings that the mother and the father endangered the child’s physical or emotional well-being. Consequently, we hold that the evidence is legally and factually sufficient to support the trial court’s finding as to each parent under Section 161.001(b)(1)(E).

A parent’s continuing illegal substance abuse can support an endangerment finding under section 161.001(b)(1)(E).

in the Interest of N.R. and J.R., II., Children · filed 2019-01-31(b)(1)(E)

Given the evidence of illegal substance abuse both before the children’s removal and during their brief return, ... we conclude that the record supports Father’s tacit admission that he endangered the children’s well-being as described in subsection E.

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

in the Interest of U. G. G. a Child · filed 2019-02-26(b)(1)(E)

Having consider the evidence in the light most favorable to the trial court’s finding, we conclude that a reasonable fact finder could have formed a firm belief or conviction that Father engaged in a course of conduct endangering to U.G.G.’s physical and emotional well-being under Section 161.001(b)(1)(E).

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

in the Interest of A. F.J and A. K .R. Children · filed 2019-03-01(b)(1)(E)

Having considered the evidence in the light most favorable to the trial court’s finding, we conclude that a reasonable fact finder could have formed a firm belief or conviction that Mother engaged in a course of conduct endangering to the children’s physical and emotional well-being under section 161.001(b)(1)(E).

A parent’s course of criminal activity and drug use can support an endangerment finding under subsection (b)(1)(E), even though imprisonment alone cannot.

in the Interest of J.D.S., a Child · filed 2019-03-07(b)(1)(E)

We cannot hold that the finding made by the trial court pursuant to Section 161.001(b)(1)(E) was not supported by clear and convincing evidence; the evidence is both legally and factually sufficient to support the finding.

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

in the Interest of M.D.E., a Child v. Texas Department of Family and Protective Services · filed 2019-03-12(b)(1)(E)

Given Mother’s physical abuse of the children, erratic behavior, criminal history and incarceration, and absence from the children’s lives, the trial court could have found that Mother engaged in conduct that endangered the physical or emotional well-being of K.T.E., M.A.E., and M.D.E.

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

in the Interest of K.T.E., and M.A.E., Children · filed 2019-03-12(b)(1)(E)

We conclude the evidence is legally and factually sufficient to support the predicate termination finding under subsection (E).

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows that a parent’s conduct endangered a child’s physical or emotional well-being, including repeated exposure to domestic violence.

in the Interest of J.B.M., L.P.B., B.C.B., G.L.B. II, and G.G.B., Children · filed 2019-03-13(b)(1)(E)

Therefore, the evidence is legally and factually sufficient to support the trial court’s finding under section 161.001(b)(1)(E) of the Texas Family Code.

A parent's drug use and domestic violence in the home can support termination under subsection (b)(1)(E) when they endanger a child's physical or emotional well-being.

in the Interest of W.D and C.D., Children · filed 2019-03-20(b)(1)(E)

Given the record, we conclude that the evidence of both parents' drug use, which resulted in the children testing positive for marijuana, and the domestic violence in the parents' home, viewed in the light most favorable to the subsection (E) finding, was sufficiently clear and convincing that a reasonable factfinder could have formed a firm belief or conviction that Linda and William 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.

Section 161.001(b)(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 F.M.E.A.F., A.A.F.H., and A.J.F.H., Children · filed 2019-03-21(b)(1)(E)

A reasonable factfinder could have formed a firm belief or conviction that Mother violated Section 161.001(b)(1)(E), and the disputed evidence is not so significant that a factfinder could not reasonably have formed a firm belief or conviction.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child; continued illegal drug use after removal can support an endangerment finding.

in the Interest of M.M. and C.M., Children · filed 2019-03-28(b)(1)(E)

Even without considering her refusal to submit to drug testing, Mother’s admission of illegal drug use after the children were removed supports the district court’s endangerment finding. ... Considered in the light most favorable to the district court’s finding, we conclude that the evidence is legally sufficient to support the district court’s termination of Mother’s parental rights under section 161.001(b)(1)(E) under these circumstances.

Subsection (b)(1)(E) treats cultivating large quantities of marijuana in a child’s home as an endangering course of conduct.

in the Interest of L.M., a Child · filed 2019-04-09(b)(1)(E)

Cultivating large quantities of marijuana in a residence where a child is living is an endangering course of conduct to the child.

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

in the Interest of C.A.G. III, a Child · filed 2019-04-09(b)(1)(E)

Based on the evidence presented, the trial court reasonably could have formed a firm belief or conviction that terminating Mother’s parental rights was justified under Family Code section 161.001(b)(1)(E) and was in Carter’s best interest.

Section 161.001(b)(1)(E) requires a voluntary, deliberate, and conscious course of parental conduct that endangers the child’s physical or emotional well-being.

in the Interest of A.J.R. A/K/A A.J.R., a Child v. Texas Department of Family and Protective Services · filed 2019-04-09(b)(1)(E)

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.

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

in the Interest of E. v. V, M.-H., Jr. v. Department of Family and Protective Services · filed 2019-03-28(b)(1)(E)

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

Section 161.001(b)(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 M.C. · filed 2019-04-11(b)(1)(E)

We conclude the Department established, by clear and convincing evidence, that June committed the predicate act enumerated in section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) treats a parent’s course of conduct that endangers a child, including accepting another person’s endangering conduct, as a predicate ground for termination.

in the Interest of J.J.W., C.T.Y., C.E.Y., C.W.Y., and A.J.K., Children · filed 2019-04-25(b)(1)(E)

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)(E).

A parent’s illicit drug use during pregnancy can constitute endangering conduct supporting termination of parental rights.

in the Interest of I. T., Children v. Department of Family and Protective Services · filed 2019-05-07(b)(1)(E)

There is clear and convincing evidence that Laura knowingly used illicit drugs during pregnancy. The evidence is sufficient to support the trial court’s judgment terminating Laura’s parental rights to Ian under Subsection (E).

Section 161.001(b)(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 P. M., a Child · filed 2019-05-09(b)(1)(E)

Because we determine that there was sufficient evidence supporting subsection (E), we need not reach Mother’s challenges to the trial court’s findings under subsections (D) or (O).

Repeated methamphetamine use can support termination when it forms a course of conduct that endangers a child’s physical or emotional well being.

in the Interest of B. S. and M. R., Children · filed 2019-05-15(b)(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to support termination of B.S.’s parental rights under subsection (E) of Texas Family Code Section 161.001(b).

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

C. S. B. v. Texas Department of Family and Protective Services · filed 2019-05-16(b)(1)(E)

On this record, we cannot say that a reasonable factfinder could not have formed a firm belief or conviction that Mother’s conduct endangered Kaylee’s physical well-being. See Tex. Fam. Code § 161.001(b)(1)(E); Smith, 2003 WL 22096141, at *14.

Section 161.001(1)(D) and (E) permit termination for endangerment when sufficient evidence also shows that termination is in the child’s best interest.

Hann v. Texas Department of Protective & Regulatory Services · filed 1998-06-17(1)(D), (1)(E)

After considering all the evidence, we find that it was highly probable that the trial court could reasonably conclude that the child was endangered according to Sections 161.001(1)(D) & (E).

Section 161.001(1)(D) and (E) permit termination when parental conduct creates an unstable environment that endangers a child's physical or emotional well-being.

in the Interest of S.D. & K.D., Children · filed 1998-08-31(1)(D), (1)(E)

An environment which routinely subjects a child to the probability that she will be left alone because her parents are once again jailed, whether because of the continued violation of probationary conditions or because of a new offense growing out of a continued use of illegal drugs, or because the parents are once again committed to a rehabilitation program, endangers both the physical and emotional well-being of a child. Conduct that results in such disability, and conduct that subjects a child to a life of uncertainty and instability, endangers the physical and emotional well-being of a child.

Under the endangerment grounds, a parent who knows of alleged sexual abuse can endanger children by returning them to the home where it occurred, even when the alleged abusers are absent during a visit.

In Re RG · filed 2001-10-31(1)(D), (1)(E)

Whether or not the brothers were present at the time that Gomez left his children at his mother's house is irrelevant. The fact remains that he knowingly left the children in the home of the alleged perpetrators, in a place where sexual abuse had allegedly occurred in the past and where the children were vulnerable to potential abuse in the future. ... Therefore, having reviewed all of the evidence, we find that the evidence is factually sufficient to prove both grounds for termination.

Section 161.001(1)(D) addresses endangerment caused by a child’s environment, while (1)(E) addresses endangerment caused by a parent’s acts or omissions.

In the Interest of H.C. · filed 1997-02-19(1)(D), (E)

These alternatives are distinguished by the cause of the children’s physical or emotional endangerment. ... “Under subsection (D), it must be the environment which causes the child’s physical or emotional well-being to be endangered, as distinguished from the parent’s conduct. Under subsection (E), the cause of the danger to the child must be the parent’s conduct alone, as evidenced not only by the parent’s acts but also by the parent’s omissions or failures to act.”

Section 161.001 permits termination when any one listed ground is proved and termination is in the child’s best interest.

Edwards v. Texas Department of Protective & Regulatory Services · filed 1997-05-08(1), (2)

The relevant statute allows for termination of parental rights on fourteen alternative grounds. A finding on any one ground, coupled with a finding that termination is in the best interest of the child, is sufficient to terminate parental rights.

Section 161.001 requires clear and convincing evidence of a listed act or omission and that termination is in the child’s best interest.

In the Interest of C.D. · filed 1998-01-08

In proceedings to terminate the parent-child relationship brought under section 161.001 of the Family Code, the petitioner must establish by clear and convincing evidence one or more of the acts or omissions enumerated under subdivision (1) of the statute and must additionally prove, as required under subdivision (2), that termination of the parent-child relationship is in the best interest of the child.

Grounds for termination under Section 161.001 must be pleaded before they can support a termination judgment.

In the Interest of B.B. · filed 1998-06-25(1)

While under § 161.001(1)(A), (B), (F), (N)(i), (ii) and (iii), these are grounds for termination, they must be pleaded in order to support the trial court’s judgment.