Tex. Fam. Code Ann. § 161.001

Section 161.001(1)(D) and (E) allow termination based on endangering surroundings or a parent’s endangering course of conduct when the grounds are proved by clear and convincing evidence.

in the Interest of M.A.C., a Child · filed 2012-10-11(1)(D), (1)(E)

Applying the appropriate standards of review, we hold that the evidence is legally and factually sufficient to support the trial court’s findings that Father engaged in conduct or knowingly placed M.A.C. with persons who had engaged in conduct that endangered her physical or emotional well-being and that he knowingly placed or knowingly allowed M.A.C. to remain in conditions or surroundings that endangered her physical or emotional well-being.

Section 161.001(1)(D) and (E) require clear and convincing evidence that a parent exposed a child to endangering surroundings or engaged in a course of endangering conduct.

in the Interest of K.E.S., a Child · filed 2012-09-20(1)(D), (1)(E)

The evidence thus is legally and factually insufficient to support termination under both subsections (D) and (E) of section 161.001(1).

Subsection (1)(D) permits termination for knowingly placing a child in an endangering environment; subsection (1)(E) permits termination for an endangering course of parental conduct, including failures to act.

A. S. v. Texas Department of Family and Protective Services · filed 2012-12-21(1)(D) and (E)

We find the evidence presented legally sufficient to support termination under Sections 161.001(1)(D) & (E).

Section 161.001(1)(D) and (E) allow termination when clear and convincing evidence shows that a parent endangered a child through dangerous surroundings or the parent’s conduct, and termination is in the child’s best interest.

in the Interest of P.-L.M.M., a Child · filed 2012-11-01(1)(D), (1)(E)

Applying the appropriate standards of review, we hold that the evidence is legally and factually sufficient to support the trial court’s findings that Mother engaged in conduct that endangered P.-L.M.M.’s physical or emotional well- being and that Mother knowingly placed or knowingly allowed P.-L.M.M. to remain in conditions or surroundings that endangered P.-L.M.M.’s physical or emotional well-being.

Section 161.001(1)(D) and (E) permit termination when clear and convincing evidence establishes endangerment through the child’s surroundings or the parent’s conduct.

in the Interest of E.M.M., Jr., Minor Child · filed 2012-12-21(1)(D), (E)

Because the evidence was legally and factually sufficient to support the jury’s endangerment findings, we overrule Father’s first two issues.

Subsections (1)(D) and (E) address an environment that endangers a child and a parent’s course of endangering conduct, respectively.

in the Interest of I.C.W. and S.R.R.W., Children · filed 2013-01-17(1)(D), (1)(E)

The evidence is legally and factually sufficient to support the trial court’s findings that Mother and Father engaged in conduct proscribed by subsections (D) and (E) of section 161.001(1).

Subsections (1)(D) and (E) permit termination for endangerment when adults operate a prostitution service from the family home amid violent and unstable conditions.

in the Interest of N. K., a Child · filed 2013-03-25(1)(D), (E)

Based on evidence that Bethany and the two other adults in the home engaged in prostitution from the family home for a number of months, especially when considered with evidence of violent, unstable, and unsanitary living conditions, Michael's admission of sexual abuse of N.K., and Bethany's lack of concern about such admission, the trial court sitting as finder of fact could have formed a firm belief or conviction that Bethany endangered the physical or emotional well-being of the children or placed the children in conditions or surroundings which endangered their physical or emotional well-being. See Tex. Fam. Code Ann. § 161.001(1) (D), (E).

Subsections (1)(D) and (E) permit termination when a parent’s conduct or a child’s home conditions endanger the child’s physical or emotional well-being, even if the child suffers no actual injury.

Holliday v. State · filed 2013-03-25(1)(D), (E)

All that being said, the record establishes the group’s at-home prostitution operation directly and indirectly endangered the children’s physical and emotional well-being.

Section 161.001(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent allowed a child to remain in endangering surroundings or engaged in conduct that endangered the child.

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

Based on the record before us, we conclude a reasonable fact finder could have formed a firm belief or conviction that Mother allowed the child to remain in surroundings that endangered T.A.D. We also conclude that a reasonable fact finder could have formed a firm belief that she engaged in conduct and knowingly placed the child with a person who engaged in conduct that endangered the physical and emotional well-being of T.A.D. Thus, we hold that the evidence supporting termination under section 161.001(1) (D) & (E) of the family code 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, including conduct after the child's removal.

in the Interest of G.W. and K.K., Children · filed 2013-04-18(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 trial court's finding pursuant to section 161.001(1)(E).

Section 161.001(1)(D) and (E) permit termination when a parent endangers a child through the child’s surroundings or the parent’s conduct, if termination is also in the child’s best interest.

in Re G. A. A., a Child · filed 2013-04-25(1)(D), (1)(E)

Thus, we hold that the evidence was legally and factually sufficient to support the trial court’s termination of J.S.E.’s parental rights pursuant to subsections 161.001(1)(D) & (E).

Section 161.001(1)(D) and (E) permit termination when a parent knowingly leaves children in endangering surroundings or engages in conduct that endangers their physical or emotional well-being.

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

We conclude, based on these findings, that there was clear and convincing evidence that T.M. and H.M. (1) knowingly placed or knowingly allowed A.M. and C.M. to remain in conditions or surroundings which endangered their physical or emotional well-being, see TEX. FAM. CODE ANN. § 161.001(1)(D), and (2) engaged in conduct or knowingly placed A.M. and C.M. with persons who engaged in conduct which endangered their physical or emotional well-being, see id. § 161.001(1)(E).

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

in the Interest of A.L.R. and M.R.R., Children · filed 2013-05-13(1)(E)

This is both legally and factually sufficient evidence supporting the conclusion that Shawn 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(1)(D) and (E) permit termination when a parent knowingly leaves a child in endangering surroundings or knowingly places the child with a person whose conduct endangers the child.

in the Interest of A.T., a Child · filed 2013-07-10(1)(D), (1)(E)

Accordingly, considering the record as a whole, the fact-finder could reasonably form a firm conviction or belief Mother and Father violated subsections 161.001(1)(D) and (E) by knowingly allowing A.T. to remain in conditions that endangered his physical and emotional well-being and knowingly placing A.T. with a person who engaged in conduct that endangered his emotional and physical well-being.

Section 161.001(1)(D) and (E) allow termination when the evidence supports findings of endangering conditions or conduct.

in the Interest of A.N.D. and A.T.D., Children · filed 2013-09-26(1)(D), (1)(E)

The application of the record before us to the guiding legal principles regarding subsections (D) and (E) result in our determination that the evidence is both legally and factually sufficient to support the trial court‘s determination that Arman had committed the predicate grounds alleged in the Department‘s amended petition.

Section 161.001(1)(D) and (E) allow termination when clear and convincing evidence shows that a parent knowingly exposed a child to endangering conditions or engaged in endangering conduct.

in the Interest of I.R. and J B., Children · filed 2013-10-31(1)(D), (1)(E)

We hold that the evidence is legally and factually sufficient to support the trial court’s findings under Section 161.001(D) and (E) because the trial court could reasonably have formed a firm belief or conviction that the mother knowingly placed or knowingly allowed the children to remain in conditions or surroundings that endangered their physical or emotional well-being and that the mother had engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered their physical or emotional well-being.

Section 161.001(1)(D) and (E) allow endangerment to serve as a ground for termination when clear and convincing evidence shows that the child’s surroundings or the parent’s conduct endangered the child.

in the Interest of F.H. A/K/A F.A., H.H., and B.H., Children · filed 2014-02-24(1)(D), (1)(E)

We hold that there was clear and convincing evidence from which the trial court could reasonably have formed a firm belief that both parents (1) knowingly placed or knowingly allowed the children to remain in conditions or surroundings that endangered their physical or emotional well-being or (2) 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.

The evidence was legally insufficient to support termination under subsections (1)(D) and (1)(E).

in the Interest of C.N., R.N. and D.N., Children · filed 2014-05-30(1)(D), (1)(E)

Therefore, we conclude that the evidence is legally insufficient to support a finding of termination of D.N.’s parental rights under Section 161.001(1)(D) of the Texas Family Code. ... Therefore, we conclude that the evidence is legally insufficient to support a finding of termination of D.N.’s parental rights under Section 161.001(1)(E) of the Texas Family Code.

The evidence was legally insufficient to support termination under subsections (1)(D) and (1)(E).

in the Interest of C.N., R.N. and D.N., Children · filed 2014-07-09(1)(D), (1)(E)

Therefore, we conclude that the evidence is legally insufficient to support a finding of termination of D.N.’s parental rights under Section 161.001(1)(D) of the Texas Family Code. ... Therefore, we conclude that the evidence is legally insufficient to support a finding of termination of D.N.’s parental rights under Section 161.001(1)(E) of the Texas Family Code.

Section 161.001(1)(D) and (E) permit termination for endangering conditions or conduct when supported by clear and convincing evidence.

in the Interest of A.R., the Child · filed 2014-07-17(1)(D), (E)

We hold that the evidence is legally and factually sufficient to support the jury’s family code subsection 161.001(1)(D) and (E) endangerment findings.

The evidence supported termination under subsections (1)(D) and (1)(E).

in the Interest of I.R.K.-N., a Child · filed 2014-05-15(1)(D), (1)(E)

The evidence is legally and factually sufficient to support the jury’s findings that Amy’s parental rights should be terminated under subsections 161.001(1)(D) and 161.001(1)(E).

Section 161.001(1)(D) permits termination when a child’s surroundings endanger the child, and subsection (1)(E) permits termination when a parent’s conduct endangers the child.

in the Interest of D.E.R., T.M.A., S.N.H. and T.W.H., Children · filed 2014-06-05(1)(D), (1)(E)

In this case, there was evidence that the children were exposed to dangerous equipment and drugs inside their home. Thus, a finding under subsection (D) was supported because the children’s environment was the source of danger. With respect to subsection (E), the evidence showed that the parents used drugs and were involved in drug trafficking. Such acts constituted conduct that endangered the children.

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

in the Interest of K.P., K.P. and K.P. · filed 2014-08-21(1)(D), (1)(E)

We hold that the evidence is legally and factually sufficient to support the trial court’s decision to terminate Mother’s and Father’s parental rights under subsections (D) and (E).

The evidence supported the statutory predicate under subsections (1)(D) and (1)(E).

J. D. S. v. Texas Department of Family and Protective Services · filed 2014-09-24(1)(D), (1)(E)

Based on the undisputed evidence, the trial court could have reasonably formed a firm belief or conviction that JDS violated subsections 161.001(1)(D) and (E). The evidence is thus legally and factually sufficient to support the statutory predicate.

Subsections (1)(D) and (E) permit termination when a parent knowingly exposes a child to endangering surroundings or engages in conduct that endangers the child.

in the Interest of R.L.G., Children · filed 2014-10-01(1)(D), (E)

Despite the conflicting evidence, we hold that a factfinder could have reasonably formed a firm conviction or belief that Mother knowingly placed or knowingly allowed the children to remain in conditions or surroundings that endangered their emotional or physical well-being and that Mother engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered their physical or emotional well-being.

Section 161.001 permits termination when clear and convincing evidence shows that a parent endangered a child through the child’s surroundings or the parent’s conduct.

in the Interest of A.L., D.R.L., and N.S.L. · filed 2014-10-15(1)(D), (1)(E)

Having reviewed all the evidence, we conclude that a reasonable factfinder could have formed a firm belief or conviction that Joseph endangered the children and that its findings under sections 161.001(1)(D) and (E) were true.

Section 161.001(1)(D) and (E) allow termination when a parent’s conduct or the conditions in which a child remains endanger the child, even if the conduct was not directed at that child.

in the Interest of S. S., a Child · filed 2015-01-19(1)(D), (1)(E)

We conclude the evidence is legally and factually sufficient to support the trial court’s finding that Mother engaged in conduct or placed or allowed S.S. to remain in conditions, surroundings, or with persons that endangered S.S.’s physical or emotional well-being. See TEX. FAM. CODE ANN. § 161.001(1)(D), (E); Boyd, 727 S.W.2d at 533 (holding endangerment can be proven through conduct not directed at the child but that threatens child’s physical and emotional well-being).

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

in the Interest of S.R., S.R. and B.R.S., Children · filed 2014-11-13(1)(D), (1)(E)

We hold the evidence is legally and factually sufficient to support the predicate termination findings under subsections D and E.

The evidence supported an endangerment finding by clear and convincing evidence.

in the Interest of H.A.G., a Child · filed 2014-11-21(1)(D), (E)

After reviewing the record as a whole, we hold that a reasonable trier of fact could have formed a firm belief or conviction that Xiomara knowingly endangered H.A.G.’s well-being.

The father’s relocation, drug use, and lack of contact could support a finding that his instability continued.

in the Interest of S.G., I.G., and B.G., Children · filed 2015-01-29(1)(D), (E)

The trial court could have properly found that Father’s moving to California after the removal without staying in regular contact with TDFPS or the children, his drug use there, and his failure to provide a lease agreement evidenced that his pattern of instability continued or that it at least had not been permanently replaced by stability.

The evidence supported endangerment findings under subsections (1)(D) and (1)(E).

in Re A.M.B., S.M.B., A.M.B., F.M.B. A/K/A F.B., S.M.B. A/K/A S.M., and M.M.B., Children · filed 2014-12-17(1)(D), (1)(E)

Viewing all of this evidence 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 the parents (1) knowingly placed or knowingly allowed their children to remain in conditions or surroundings which endangered their physical or emotional well-being and (2) engaged in conduct or knowingly placed their children with persons who engaged in conduct that endangered the children’s physical or emotional well-being.

The court upheld termination under the two endangerment grounds in subsections (1)(D) and (1)(E).

in the Interest of B.E.T., a Child · filed 2015-02-05(1)(D), (1)(E)

Accordingly, we find that the evidence was legally and factually sufficient to support the trial court’s findings that termination was warranted under Texas Family Code Section 161.001(1)(D) and (E).

The court upheld a child-endangerment finding supporting termination under subsection (1)(E).

in the Interest of I.L.M. · filed 2015-03-17(1)(E)

We further hold that the evidence was legally and factually sufficient to support the father’s parental-rights termination based on child endangerment.

The court upheld termination under the section’s endangerment grounds after reviewing legal and factual sufficiency.

in the Interest of G.H. and G.H., Children · filed 2015-03-19(1)(D)–(E)

Applying the appropriate standards of review, we hold that the evidence is legally 8 and factually 9 sufficient to support the trial court’s endangerment findings ... against Father.

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 G.H. and G.H., Children · filed 2015-03-23(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.

Under subsections (1)(D) and (E), drug use in the home can support a finding that a child was endangered.

in the Interest of S v. K v. and E v. Children · filed 2015-03-24(1)(D), (E)

Drug use in the home is relevant evidence on the issue of endangerment. ... When applying the proper standard of review to George’s legal sufficiency argument regarding subsections (D) and (E), we find that a reasonable trier of fact could have formed a firm belief or conviction as to the truth of the allegations sought to be established.

Section 161.001(1)(D) and (E) provide grounds for termination based on conditions or conduct that endanger a child’s physical or emotional well-being.

C. W. v. Texas Department of Family and Protective Services · filed 2015-05-01(1)(D), (1)(E)

Legally sufficient evidence supported the trial court’s conclusion that appellant endangered the children’s physical and emotional well-being under both grounds.

The court upheld termination under both endangerment grounds in subsections (1)(D) and (E).

in the Interest of J.N. · filed 2015-05-21(1)(D), (E)

We conclude that the evidence is legally and factually sufficient to support the trial court’s decision to terminate Jane’s parental rights under section 161.001(1)(D) and (E).

Section 161.001(1)(D) and (E) allow termination when a child’s environment or a parent’s conduct endangers the child’s physical or emotional well-being, including through repeated domestic violence.

in the Interest of E. K., B. G., and L. G., Children · filed 2015-05-14(1)(D), (1)(E)

Mother’s self-injurious behavior in front of the children, her involvement in repeated domestic violence with father and denial of the same, and her failure to remove herself and the children from the relationship constitutes conduct endangering the physical or emotional well-being of the children. ... The evidence is legally and factually sufficient to support the trial court’s findings under sections 161.001(1)(D) and (E) and that termination is in the best interest of the children.

Section 161.001(1)(D) permits termination for an endangering environment, while (1)(E) permits termination for an endangering course of parental conduct.

in the Interest of E.M. and J.M., Children · filed 2015-05-28(1)(D), (1)(E)

The evidence is legally and factually sufficient to support the jury's findings that Jessica's parental rights should be terminated under subsections 161.001(1)(D) or 161.001(1)(E).

The court upheld endangerment findings under subsection (b)(1)(D) and (E).

in the Interest of M.N., V.W., and Z.W., Children · filed 2015-05-28(b)(1)(D)–(E)

Based on the appropriate standards of review, we hold that the evidence is legally 5 and factually 6 sufficient to support the trial court’s endangerment findings against Mother.

Section 161.001(1)(D) and (E) allow termination when a parent knowingly exposes children to an endangering environment or engages in conduct that endangers them.

in the Interest of A.A.L.A, F.K.A, and C.M.A., Children · filed 2015-09-15(1)(D), (E)

Because appellant had a long and continuing history of criminal behavior, which endangered the children, and he knew Mother was endangering the children by using drugs while they were living with her, we conclude the evidence is legally and factually sufficient to support the trial court’s findings under subsections D and E of section 161.001(1) of the Texas Family Code.

Knowingly placing children with a complete stranger can support termination under subsections (b)(1)(D) and (E) when it endangers their well-being.

in the Interest of R.S. and A.S., Children · filed 2015-10-01(b)(1)(D), (b)(1)(E)

Mother’s knowingly placing her children with a complete stranger endangered the well-being of her children and therefore supports termination under subsections (D) and (E).

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 M.G., B.G., S.G., and A.Z., Children · filed 2015-12-15(1)(E)

Reviewing the evidence under the appropriate standards, we conclude that the jury could have formed a firm belief or conviction that termination of the parents’ rights is warranted under section 161.001(1)(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 S.L.S., S.S., S.L.S., Children · filed 2016-06-01(b)(1)(E)

The trial court could have reasonably formed a firm belief or conviction that Christopher engaged in a voluntary, deliberate, and conscious course of conduct that endangered the children’s physical or emotional well-being. We therefore hold the evidence is legally and factually sufficient to support the trial court’s finding of the endangerment ground of termination and need not address Christopher’s issue that the Department failed to plead the incarceration ground.

Section 161.001(b)(1)(E) permits an endangerment finding based on a parent's illegal drug use during a termination suit and does not require a course of conduct.

In the INTEREST OF A.M. & A.M., Children · filed 2016-07-28(b)(1)(E)

However, the statute does not require “a course of conduct.” The evidence shows that the father engaged in illegal drug use during the pendency of this termination suit, and no evidence directly contradicts that. Considering the entire record, we hold that the evidence is factually sufficient to support the trial court’s finding.

Subsection (b)(1)(E) permits termination when a parent’s acts or omissions endanger a child’s physical or emotional well-being.

in the Interest of J.W., a Child · filed 2016-08-04(b)(1)(E)

Because we hold that the evidence is legally and factually sufficient to support the jury verdict, we affirm the trial court’s judgment. ... Under subsection (E), the relevant inquiry is whether evidence exists that the endangerment of the child’s physical or emotional well-being was the direct result of the parent’s conduct, including acts, omissions, and failures to act.

Subsections (b)(1)(D) and (E) permit termination when a parent knowingly exposes a child to endangering conditions or engages in a deliberate course of endangering conduct.

in the Interest of I.G., I.G., T.R., and F.R. Jr., Children · filed 2016-09-30(b)(1)(D) and (E)

Consequently, we hold that the evidence is legally and factually sufficient to support the trial court’s findings under Section 161.001(b)(1)(D) and (E).

Subsections (b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent knowingly kept children in endangering conditions or engaged in conduct that endangered them.

in the Interest of J.N., M.N., and M.N., Children · filed 2017-02-22(b)(1)(D), (E)

We therefore hold that the evidence is factually sufficient to establish that Appellant violated Family Code subsections 161.001(b)(1)(D) and (E).

Section 161.001(b)(1)(E) requires a voluntary, deliberate course of conduct that endangers a child’s physical or emotional well-being; untreated mental illness and criminal activity can support that finding.

in the Interest of D.L.T.Jr., a Child · filed 2017-10-19(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. ... The evidence shows Mother’s untreated mental illness and criminal activity endangered David. ... Accordingly, the evidence is legally and factually sufficient to support the trial court’s finding under subsection E.

Subsections (b)(1)(D) and (E) permit termination when a parent knowingly leaves a child with a known drug user, exposing the child to an endangering environment and conduct.

in the Interest of A.T., a Child · filed 2017-10-26(b)(1)(D), (E)

Giving due deference to the factfinder’s endangering-environment and endangering-conduct findings, without supplanting the factfinder’s judgment with our own, and after reviewing the entire record, we hold that a factfinder could reasonably form a firm conviction or belief that Father had knowingly placed or had knowingly allowed Andrew to remain in conditions or surroundings that had endangered his emotional or physical well-being and that Father had engaged in conduct or had knowingly placed Andrew with persons who had engaged in conduct that had endangered his physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) allow termination when a parent endangers a child through the child's conditions or the parent's conduct, if termination is also in the child's best interest.

in the Interest of L. D. Child v. Department of Family and Protective Services · filed 2017-12-14(b)(1)(D), (b)(1)(E)

We conclude that a reasonable factfinder could have formed a firm belief that L.D. was physically or emotionally endangered by the conditions in which his parents placed him, or by their conduct.

A parent’s course of conduct can support termination when it endangers a child’s emotional well-being.

in the Interest of W.R.C., H.J.C., and A.J.C., Children · filed 2017-12-20(b)(1)(E)

Eric’s threats, comments, and actions show a course of conduct that endangers the children’s emotional well-being.

Subsections (b)(1)(D) and (E) permit termination when a parent knowingly leaves a child in endangering surroundings or engages in conduct that endangers the child.

in the Interest of H.L.H. and A.H., Children · filed 2018-03-14(b)(1)(D), (E)

We thus hold that the evidence is legally and factually sufficient to establish that Chad and Mia violated Family Code subsections 161.001(b)(1)(D) and (E).

Subsections (b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent knowingly leaves a child in endangering surroundings or engages in endangering conduct.

in the Interest of L.B., L.B., N.B., and A.B., Children · filed 2018-03-21(b)(1)(D), (b)(1)(E)

We hold that the evidence is legally sufficient to establish that D.B. violated Family Code subsections 161.001(b)(1)(D) and (E).

Section 161.001(b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent knowingly exposes a child to dangerous surroundings or engages in conduct that endangers the child.

v. C. and R. S. v. Texas Department of Family and Protective Services · filed 2018-06-22(b)(1)(D), (E)

Accordingly, the evidence in this record is legally and factually sufficient to support a statutory ground for termination of Mother’s parental rights under subsections 161.001(b)(1)(D) and (E) of the Family Code.

Section 161.001(b)(1)(D) and (E) permit termination when a parent endangers children through their surroundings or a course of conduct.

in the Interest of L.W. and F.W., Children · filed 2018-07-12(b)(1)(D), (b)(1)(E)

The evidence was factually sufficient to support the fact-finder’s findings that Father engaged in endangering conduct as defined in subsections (D) and (E) and that termination of Father’s parental rights was in the children’s best interest.

Section 161.001(b)(1)(D) and (E) require clear and convincing evidence of endangerment; unsupported allegations of drug use cannot sustain an endangerment finding.

In re Interest of C.M.C. · filed 2018-07-12(b)(1)(D), (E)

Reviewing all of the evidence in the light most favorable to the finding, we conclude a reasonable factfinder could not have formed a firm belief or conviction that Mother endangered C.M.C. under subsections D or E, and therefore, the evidence of endangerment is legally insufficient.

Subsection (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 X.G. and V.G., Children · filed 2018-08-30(b)(1)(E)

Reviewing all the evidence in the light most favorable to the termination finding under subsection E, we conclude that a reasonable fact finder could have formed a firm belief or conviction as to the truth of the finding that Mother endangered both children through her own conduct and by placing them in an endangering environment.

Subsections (b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent exposed children to endangering conditions or engaged in conduct that endangered them.

in the Interest of Z.T., E.B. and P.B., Children · filed 2018-09-19(b)(1)(D), (E)

Therefore, we hold that the evidence, viewed in the light most favorable to the jury’s findings, was sufficiently clear and convincing that a reasonable trier of fact could have formed a firm belief or conviction that J.T. knowingly placed or knowingly allowed the children to remain in conditions or surroundings which endangered the physical or emotional well-being of the children, and that J.T. knowingly 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)(D) and (E) permit termination when clear and convincing evidence shows a parent knowingly kept children in endangering surroundings or with a person whose conduct endangered them, and termination is in the children’s best interests.

in the Interest of J.E.P · filed 2018-10-10(b)(1)(D), (E)

Considering all the evidence in the appropriate light for each standard of review, we conclude that the trial court could have formed a firm belief or conviction that Mom’s acts or omissions violated statutory grounds (D) and (E), and terminating Mom’s parental rights to J.E.P. and E.D.P. was in the children’s best interests.

Section 161.001(b)(1)(D) and (E) provide endangerment grounds for terminating parental rights when the evidence also supports a finding that termination is in the child's best interest.

in the Interest of J.R., a Child · filed 2018-09-26(b)(1)(D), (E)

In other words, the evidence is both legally and factually sufficient to support the findings that at least one statutory ground warranted termination, ... (e.g., endangerment under § 161.001(b)(1)(D) and (E)), and that termination was in the best interest of the child.

Section 161.001(b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent exposed a child to endangering conditions or engaged in endangering conduct, provided termination is in the child’s best interest.

in the Interest of K.S. and E.S., Children · filed 2018-09-28(b)(1)(D), (E)

Viewing the evidence in the light most favorable to the termination findings under family code subsections 161.001(b)(1)(D) and (E), a reasonable factfinder could have formed a firm belief or conviction that Mother engaged in endangering conduct and exposed the children to endangering conditions.

Section 161.001(b)(1)(D) and (E) permit termination when a parent knowingly leaves children in endangering surroundings or engages in conduct that endangers their physical or emotional well-being.

in the Interest of T.B., T.B., I.B. and M.D., Jr., Children · filed 2018-10-17(b)(1)(D), (E)

The evidence was legally and factually sufficient for the trial court to have found that Shavon knowingly allowed her children to remain in surroundings that endangered their physical or emotional well-being pursuant to Subsection (D). The evidence was also legally and factually sufficient for the trial court to have found that she engaged in conduct that endangered the physical or emotional well-being of the children pursuant to Subsection (E).

Section 161.001(b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent exposed a child to endangering conditions or engaged in endangering conduct.

in the Interest of A.C., a Child · filed 2018-10-24(b)(1)(D), (E)

The evidence is legally and factually sufficient to support the jury’s affirmative termination finding based on subsection 161.001(b)(1)(D) and (E).

Section 161.001(b) requires clear and convincing evidence of at least one listed ground for termination and that termination is in the child’s best interest; a deliberate course of endangering conduct can satisfy subsection (b)(1)(E).

in the Interest of I.L., a Child · filed 2018-11-01(b)(1)(E), (b)(2)

We therefore hold that the evidence is legally and factually sufficient to support termination under section 161.001(b)(1)(E), and we overrule Mother and Father’s third issue. ... We therefore hold that the evidence is legally and factually sufficient to support termination under section 161.001(b)(2), and we overrule the parents’ fifth issue.

Section 161.001(b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent endangered a child through the child’s surroundings or the parent’s conduct.

in the Interest of F. R. G. and N. A. G., Children · filed 2018-11-05(b)(1)(D), (E)

Because the evidence is legally and factually sufficient to support termination of C.G.’s parental rights under subsections (D) and (E) of Texas Family Code Section 161.001(b)(1), we overrule C.G.’s third and fourth issues.

Section 161.001(b)(1)(D)–(E) provides termination grounds for knowingly exposing a child to endangering conditions or engaging in conduct that endangers the child’s physical or emotional well-being.

in the Interest of J.H., a Child · filed 2018-11-21(b)(1)(D)–(E)

Viewed in the light most favorable to the trial court’s decision, the entirety of the evidence was legally sufficient to allow a reasonable fact-finder to conclude that Mother’s course of conduct violated either subsection (D) or (E) of section 161.001(b)(1).

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows that a parent's course of conduct endangered a child; continued drug use and imprisonment for child endangerment can support that finding.

in the Interest of V.L.F., V.L.F., and V.L.F., Children · filed 2018-12-18(b)(1)(E)

To the contrary, the record reflects sufficient evidence to support the jury’s finding that Father endangered the children by continuing to use drugs during the pendency of the termination proceeding and imprisonment for child endangerment. Reviewing all the evidence in the light most favorable to the jury’s finding we hold that a reasonable fact finder could have formed a firm belief or conviction that the endangerment finding was true.

Subsection (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 J.J.A., A.A., L.A., D.L.C., Jr., Children · filed 2018-12-18(b)(1)(E)

Termination of parental rights under subsection 161.001(b)(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. ... Considered in the light most favorable to the trial court’s finding, the evidence is legally sufficient to support the trial court’s termination of Father’s parental rights under section 161.001(b)(1)(E).

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

in the Interest of C.W., a Child · filed 2018-12-18(b)(1)(E)

Considering all the evidence in the light most favorable to the endangerment finding, we conclude the trial court reasonably could have formed a firm belief or conviction that Father engaged in conduct described in section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) does not require a parent to know of their paternity before engaging in a course of conduct that endangers the child.

in the Interest of N.J.H., Children v. Department of Family and Protective Services · filed 2018-12-18(b)(1)(E)

Knowledge of paternity it is not a prerequisite to a showing of a parental course of conduct that endangers a child under section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) permits termination when a parent’s conduct endangers a child by posing physical risks or creating instability and uncertainty.

K. J. v. Texas Department of Family and Protective Services · filed 2018-12-28(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 K.J. 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 permits termination when clear and convincing evidence shows that a parent knowingly left a child in endangering conditions or engaged in conduct that endangered the child.

in the Interest of A.J.H., Child v. Department of Family and Protective Services · filed 2019-01-15(b)(1)(D), (E)

Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s termination findings under subsections (D) and (E).

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

in the Interest of Z.J.B., a Child · filed 2019-01-29(b)(1)(E)

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

Section 161.001(b)(1)(E) does not require endangering conduct to be directed at the child or to cause the child an actual injury.

in the Interest of J.S., a Child · filed 2019-02-07(b)(1)(E)

We note that, to support a finding that Appellant endangered J.S., Appellant’s offending conduct did not have to be directed at J.S., nor did J.S. actually have to suffer an injury.

Section 161.001(b)(1)(E) permits a finding of endangerment based on a parent’s course of conduct, including continued drug use and failure to seek prenatal care.

in the Interest of Z.Q.N., a Child · filed 2019-02-21(b)(1)(E)

Considering all the evidence in the light most favorable to the endangerment finding, we conclude the trial court reasonably could have formed a firm belief or conviction that Lisa engaged in conduct described in subsection E of section 161.001(b)(1) of the Family Code.

Subsection (b)(1)(E) permits a finding of endangerment based on a parent’s conduct that jeopardizes a child’s physical or emotional well-being.

in the Interest of T.S. and A.S. · filed 2019-03-07(b)(1)(E)

Because the evidence is legally and factually sufficient to support the trial court’s finding that Father violated the endangerment provision in subsection (E), we overrule Father’s first issue.

Section 161.001(b)(1)(E) permits termination when a parent’s conduct endangers a child, including sexual abuse of other children or failure to protect the child from drug activity.

in the Interest of B. S. C. F. AKA B. F. C. v. Department of Family and Protective Services · filed 2019-03-19(b)(1)(E)

We hold that there is legally and factually sufficient evidence to support the trial court’s finding that termination was justified under subsections (E).

Section 161.001(b)(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 A.C.S. and T.R.L., Children v. Texas Department of Family and Protective Services · filed 2019-03-21(b)(1)(E)

Accordingly, the evidence is legally and factually sufficient to support the trial court’s finding as to Paul regarding subsection E.

Subsection (b)(1)(D) permits termination for an endangering environment caused by a parental act or omission, while subsection (b)(1)(E) requires a course of parental conduct that endangers the child.

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

Applying the high standard of evidence required in parental termination cases, we hold that the evidence was sufficient to support the trial court’s findings of violations under section 161.001(b)(1)(D) and (E).

Section 161.001(b)(1)(D) and (E) allow termination when clear and convincing evidence shows that a parent exposed children to endangering surroundings or conduct; the children need not suffer actual injury.

in the Interest of L.W. and L.W. v. Department of Family and Protective Services · filed 2019-04-09(b)(1)(D), (E)

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

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 A.R.G., a Child v. Texas Department of Family and Protective Services · filed 2019-04-18(b)(1)(E)

Ultimately, Mother’s behavior created potential danger for Alice, which Mother consciously disregarded. This lack of concern for Alice’s well-being and shirking of parental responsibilities with regard to Ethan and Alex, supports termination under subsection (E).

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

in the Interest of S.S., a Child · filed 2019-04-18(b)(1)(D), (E)

Sufficient endangerment evidence on many fronts supports the trial court’s endangerment findings.

Section 161.001(b)(1)(D) and (E) address endangerment through a child’s surroundings or a parent’s conduct, respectively.

in the Interest of J.S. and J.S., Children · filed 2019-04-25(b)(1)(D) and (E)

Consequently, we hold that the evidence is legally and factually sufficient to support the trial court’s findings under Section 161.001(b)(1)(D) and (E).

Section 161.001(b)(1)(E) permits termination when a parent knowingly places children with someone whose conduct endangers their physical or emotional well-being, even if the children suffer no actual injury.

in the Interest of C.M., M.M., and V.M. · filed 2019-05-08(b)(1)(E)

We hold the evidence is legally and factually sufficient to support the trial court’s finding of knowing endangerment under section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) permits repeated positive drug tests to support an endangerment finding without expert testimony interpreting the results.

in the Interest of G.C., a Child · filed 2019-05-09(b)(1)(E)

Accordingly, we conclude the trial court reasonably could have relied on the drug test results in terminating Father’s parental rights under section 161.001(b)(1)(E) without accompanying expert witness testimony.

A parent’s violent criminal conduct can support an endangerment finding under subsection (b)(1)(E).

in the Interest of M.T.R., a Child v. Texas Department of Family and Protective Services · filed 2019-05-16(b)(1)(E)

Applying the applicable standards of review, we conclude the evidence is legally and factually sufficient to support the trial court’s finding under subsection E of section 161.001(b)(1) that Mother endangered Michael.

A parent’s prior sexual abuse of another child can support an endangerment finding when that conduct continues to bear on the present.

in the Interest of T.L.E. A/K/A T.E., and D.V.E A/K/A A.D.E., Children · filed 2019-05-21(b)(1)(E)

Therefore, evidence of Father’s prior conviction for indecency with a child by contact is sufficient to support the trial court’s endangerment finding under section 161.001(b)(1)(E).

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

in the Interest of K. A. C., K. C., M. C. and E. C., Children · filed 2019-06-04(b)(1)(E)

Accordingly, we find the evidence factually sufficient to support the trial court’s 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, including drug use that creates a risk of overdose or death.

in the Interest of A.G., a Child v. Texas Department of Family and Protective Services · filed 2019-06-06(b)(1)(E)

The potential for overdose or death exposes a child to loss or injury that constitutes endangerment 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; violence and illicit drug use can support that finding.

in the Interest of B.W., a Child · filed 2019-06-06(b)(1)(E)

Thus, we conclude that this evidence is sufficient to allow the trial court as factfinder to determine that Father had engaged in conduct that endangered Blake’s physical or emotional well-being.

Section 161.001(b)(1)(E) permits termination when a parent’s conduct, or knowingly placing children with others, endangers the children’s physical or emotional well-being.

in the Interest of D.C. and E.C.-B., Children · filed 2019-06-13(b)(1)(E)

Based on all the evidence introduced in this case, we conclude that a rational fact-finder could readily have reached the necessary firm conviction or belief that Judy engaged in conduct or knowingly placed Dora and Ethan with persons who engaged in conduct which endangered their physical or emotional well-being. Accordingly, we find the evidence legally and factually sufficient to support the fact-finder’s Ground E findings.

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, even if the parent was absent when the child was removed.

in the Interest of A.E.T. and A.D.T., Children · filed 2019-06-19(b)(1)(E)

Accordingly, we hold that the evidence was legally and factually sufficient to support the subsection (E) finding.

Subsections (D) and (E) allow courts to consider a child’s environment and endangering conduct before the Department removed the child.

in the Interest of M.D.M.. T.L.H. and J.D.B. Children v. Department of Family and Protective Services · filed 2019-06-13(b)(1)(D), (b)(1)(E)

Subsections (D) and (E), however, do not require courts to look solely to the child’s environment or endangering conduct occurring at the precise time DFPS became involved with the child and removed the child from the home. Instead, we are to consider the child’s environment before the Department’s removal of the child.

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

in the Interest of B.G.G., A/K/A A.G., and J.J.G., A/K/A J.G., Children v. Texas Department of Family and Protective Ser · filed 2019-06-20(b)(1)(E)

Applying the applicable standards of review, we conclude the evidence is legally and factually sufficient to support the trial court’s findings that (1) Mother endangered Josh and Ana under subsection E of section 161.001(b)(1), and (2) termination of Mother’s parental rights is in the children’s best interest.

Section 161.001(b)(1)(E) permits termination for endangering conduct, which can include delaying needed medical treatment for a child.

in the Interest of A.-N.L.C., a Child · filed 2019-06-26(b)(1)(E)

Such a delay in seeking medical treatment can constitute endangering conduct for purposes of Subsection (E).

Subsection (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 Z.H., a Child v. Texas Department of Family and Protective Services · filed 2019-06-27(b)(1)(E)

Having concluded the evidence is legally and factually sufficient to support the trial court’s finding terminating Father’s parental rights under section 161.001(b)(1)(E) and that termination is in the Zach’s best interest, we conclude that the record evidence supports the trial court’s final order of termination.

Section 161.001(b)(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 I.A v. R.A.J., and C.N.J., Children · filed 2019-08-01(b)(1)(E)

The evidence is legally and factually sufficient to show by clear and convincing evidence that the mother engaged in a continuing course of conduct that endangered the children’s physical or emotional well-being; therefore, we overrule her first issue on appeal.

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

in the Interest of L.E., a Child · filed 2019-08-15(b)(1)(E)

Thus, the evidence supports the trial court’s finding that the mother (1) had engaged in conduct that endangered L.E.’s physical or emotional well-being or (2) had knowingly placed L.E. with the father who engaged in conduct that endangered L.E.’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 the mother under Section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) permits termination when a parent’s continuing illegal drug use supports a finding that the parent endangered the child’s physical or emotional well-being.

in the Interest of J. S. a Child v. Department of Family and Protective Services · filed 2019-08-20(b)(1)(E)

Based on these facts, we conclude that the trial court, as the factfinder, reasonably could have formed a firm belief or conviction that Father engaged in conduct that endangered Julie’s physical and emotional well-being.

Section 161.001(b)(1)(E) permits termination when a parent’s continuing conduct endangers a child, including persistent illegal drug use.

in the Interest of K. M., Jr. a Child v. Department of Family and Protective Services · filed 2019-08-22(b)(1)(E)

We hold that there is legally and factually sufficient evidence to support the trial court’s finding that termination of Father’s parental rights to Kevin and Karen was justified on grounds of endangerment 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 L.A.T., a Child · filed 2019-09-19(b)(1)(E)

Based on evidence presented to the trial court regarding Mother’s history with the Department, her drug use, and her continuing course of conduct, the trial court’s finding under § 161.001(b)(1)(E) that Mother placed L.A.T. in an environment that could endanger his physical or emotional well-being is supported by legally and factually sufficient evidence.

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 conduct after a prior order denying termination.

in the Interest of M.S., N.S., C.S. and K.S., Children · filed 2019-10-04(b)(1)(E)

We conclude that there was legally sufficient evidence of conduct by Father after the June 18 Order to support the trial court’s finding pursuant to Section 161.001(b)(1)(E) that Father knowingly engaged in conduct that endangered the children’s physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) allow termination when clear and convincing evidence shows that a child’s environment or a parent’s conduct endangers the child’s physical well-being.

in the Interest of A.J.S., a Child · filed 2019-08-01(b)(1)(D), (E)

We find legally and factually sufficient evidence to support the trial court’s finding by clear and convincing evidence that Mother’s conduct and the environment in which she placed A.J.S. endangered A.J.S.’s physical well-being.

Section 161.001(b)(1)(E) permits an endangerment finding based on continued cocaine use and prolonged housing and employment instability.

in the Interest of K.J.G., Jr. · filed 2019-08-21(b)(1)(E)

We therefore hold that the evidence is legally and factually sufficient to support the trial court’s findings that termination of J.J.’s parental rights was warranted under section 161.001(b)(1)(E) and (2) of the Family Code.

Section 161.001(b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent knowingly exposed a child to endangering conditions or engaged in an endangering course of conduct; conduct during pregnancy may be considered.

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

On this record, we conclude the evidence is both legally and factually sufficient to support a finding by clear and convincing evidence that Mother knowingly placed or knowingly allowed C.J.B. to remain in conditions or surroundings which endangered the physical or emotional well-being of the child. We also conclude the evidence is both legally and factually sufficient to support a finding by clear and convincing evidence that Mother consciously engaged in a course of conduct that endangered C.J.B.’s well-being.

Section 161.001(b)(1)(D) and (E) allow termination when clear and convincing evidence shows that a parent knowingly left children in endangering conditions or engaged in conduct that endangered their well-being.

in the Interest of M. R., R. R., P. R., C. R., B. R., M. R., M. H., Children · filed 2019-08-30(b)(1)(D), (E)

Viewing the evidence in the light most favorable to the verdict and considering undisputed contrary evidence, we conclude that a reasonable factfinder could form a firm belief or conviction that N.H. placed his daughters in conditions that endangered their physical or emotional well-being and engaged in conduct that endangered their physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) allow termination based on endangering living conditions or conduct without proof that the child suffered actual injury.

in the Interest of I. v. H. Child v. Department of Family and Protective Services · filed 2019-09-26(b)(1)(D), (E)

Accordingly, the evidence is factually sufficient to support the trial court’s findings under subsections (D) and (E).

Section 161.001(b)(1)(E) requires a course of endangering conduct; a single act or omission is insufficient.

in the Interest of C.J.G., a Child · filed 2019-10-30(b)(1)(E)

Similarly, because this was evidence of only a single act or omission, the evidence regarding J.K.’s association with Solis does not support termination under subsection E.

A parent’s drug use, criminal history, lack of contact, and failure to complete a service plan can support an endangering-conduct finding under Section 161.001(b)(1)(E).

in the Interest of Z.J. and D.J., Children · filed 2019-11-21(b)(1)(E)

Whether viewed through the lens of legal or factual sufficiency, the record contains sufficient evidence—including Father’s drug use, his criminal history, his lack of contact with Jane, and his failure to complete his service plan to remedy his drug addiction—from which the factfinder could reasonably have formed a firm conviction or belief that Father’s conduct endangered Jane.

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; repeated criminal activity and resulting absences may establish endangerment.

in the Interest of J.J.D.W., J.D.W., J.J.F.W., J.L.W., J.L.J.W. AKA J.L.J.W. v. Department of Family and Protective Serv · filed 2019-11-26(b)(1)(E)

Viewing the evidence in the light most favorable to the trial court’s finding, we conclude that the trial court could have formed a firm belief or conviction that Father had engaged in conduct which endangered Julie’s, Jack’s and Jeremy’s physical or emotional well-being in violation of section 161.001(b)(1)(E).

Under subsection (b)(1)(E), abuse or medical neglect of one child can support a finding that another child was endangered.

in the Interest of J.S.A-S., a Child · filed 2019-10-11(b)(1)(E)

The jury could have inferred from Mother’s abuse of John and her medical neglect of John that George was endangered by continuing to live with Mother.

Section 161.001(b)(1)(E) requires clear and convincing evidence that the parent engaged in or knowingly placed the child with someone engaged in conduct that endangered the child’s physical or emotional well-being.

in the Interest of A.G., Jr. a Child · filed 2019-10-24(b)(1)(E)

We hold that the evidence is legally insufficient to uphold the trial court’s finding as to Appellant under subsection (E).

Section 161.001(b)(1)(D) and (E) allow termination for knowingly exposing a child to an endangering environment or engaging in endangering conduct; illegal drug use, criminal conduct, and domestic violence can support those findings.

in the Interest of K.J.B., and K.J.B., Children · filed 2019-11-05(b)(1)(D), (E)

The evidence of illegal drug use, criminal conduct, and domestic violence supports the trial court’s findings of endangerment under subsections (D) and (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, including through repeated exposure to domestic violence.

in the Interest of A.R.E. and Z.K.E., Children · filed 2019-11-05(b)(1)(E)

Having found the evidence legally and factually sufficient to support the trial court’s finding terminating Mother’s parental rights under section 161.001(b)(1)(E) and that termination is in the children’s best interest, we affirm the judgment of the trial court.

Section 161.001(b)(1)(E) allows a finding of endangerment based on a parent’s criminal conduct, incarceration, failure to support the child, prolonged absence, and placement of the child with an unstable caregiver.

T. L. v. Texas Department of Family and Protective Services · filed 2019-11-06(b)(1)(E)

Because the evidence was legally and factually sufficient to support the trial court’s finding under subsection E, we need not address Thomas’s remaining issues contesting the trial court’s other statutory predicate findings.

Section 161.001(b)(1)(E) makes a parent’s course of conduct that endangers a child a ground for termination.

in the Interest of N.S., a Child · filed 2019-11-07(b)(1)(E)

Accordingly, we hold that the evidence is legally and factually sufficient to uphold the trial court’s finding under subsection (E).

Subsections (b)(1)(D) and (E) permit termination when a parent creates a dangerous home environment or engages in an endangering course of conduct; past domestic violence can support those findings.

J. G. v. Texas Department of Family and Protective Services · filed 2019-12-04(b)(1)(D), (E)

Reviewing the record under the applicable standards, we conclude legally and factually sufficient evidence supports the trial court’s finding that Father engaged in a course of conduct that endangered the physical and emotional well-being of the children and that subjected them to a dangerous home environment. See Tex. Fam. Code § 161.001(b)(1)(D), (E).

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

in the Interest of T.L.M., A.M.M., M.N.M., and C.N.M. · filed 2019-12-19(b)(1)(E)

We conclude the evidence allowed the trial court to form a firm belief or conviction that Father engaged in conduct dangerous to Paige’s and Liam’s emotional well-being and that he knowingly placed Paige and Liam with a person who endangered them.

Section 161.001(b)(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 L.E., Z.S.A.-F. AKA Z.A., and K.A., Children · filed 2020-01-03(b)(1)(E)

Viewing the evidence before us as a whole under the requisite standards, we find sufficient clear and convincing evidence to support the trial court’s finding that the mother engaged in conduct or knowingly placed the children with persons who engaged in conduct which endangered the physical or emotional well-being of her children.

Section 161.001(b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being; illegal drug use during pregnancy and continued use after removal can support that finding.

F. C., Jr. and A. R. v. Texas Department of Family and Protective Services · filed 2020-01-09(b)(1)(E)

Considering the evidence in the light most favorable to the jury’s subsection (E) finding, we conclude that the jury could reasonably have formed a firm belief or conviction that Mother engaged in conduct that endangered the triplets’ 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; criminal conduct and imprisonment may establish that course.

in the Interest of K.R., a Child · filed 2020-01-09(b)(1)(E)

Accordingly, we hold that the evidence is legally and factually sufficient to uphold 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 R.R., Jr. a Child · filed 2020-01-16(b)(1)(E)

The clear and convincing evidence of Father’s repeated criminal conduct, convictions, imprisonment, and their collective effect on his ability to parent a child establishes an endangering course of conduct. Father has subjected Ryan to a probability of being left alone because he is in jail, endangering Ryan’s physical and emotional well-being.

Section 161.001(b)(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 H.A.S., a Child · filed 2020-01-23(b)(1)(E)

Accordingly, we hold that the evidence is legally and factually sufficient to uphold the trial court’s finding 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 S.D.T. · filed 2020-02-06(b)(1)(E)

Viewing the evidence in the light most favorable to the trial judge’s findings, we conclude that the trial judge could reasonably have formed a firm belief or conviction that J.C 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(b)(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being; medical neglect, drug abuse, and exposure to domestic violence can support that finding.

in the Interest of E.W., R.L., W.W., E.W., Children v. Texas Department of Family and Protective Services · filed 2020-02-13(b)(1)(E)

The evidence is legally and factually sufficient to support the predicate termination finding under subsection (E) as to both Mother and Father.

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 A.A.C., A.E.C, E.S.C. AKA E.C., Jr., Children · filed 2019-12-19(b)(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 Family Code section 161.001(b)(1)(E).

Subsection (b)(1)(E) permits an endangerment finding without proof that the parent’s conduct was directed at the child or caused actual injury.

in the Interest of I.G.K., a Child v. Texas Department of Family and Protective Services · filed 2020-01-07(b)(1)(E)

While endangerment often involves physical danger, the statute does not require that conduct be directed at a child or that the child actually suffer injury; rather, the specific danger to the child’s wellbeing may be inferred from the parent’s misconduct alone.

Subsection (b)(1)(E) permits termination when a parent's course of conduct endangers a child; violence and repeated drug use can support that finding.

in the Interest of J.J. and T.J., Children · filed 2020-01-28(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. Likewise, viewing the entire record, we conclude any disputed evidence is not so significant as to prevent the trial court from forming a firm belief or conviction that termination was warranted under section 161.001(b)(1)(E).

Section 161.001(b)(1)(D) and (E) permit termination for endangering surroundings or endangering parental conduct; drug use and domestic violence can support those grounds.

in the Interest of S.S., a Child · filed 2020-02-06(b)(1)(D), (b)(1)(E)

Thus, the trial court, as fact finder, could have been persuaded that Stephen’s drug use and history of domestic violence was sufficient to establish the predicate grounds set forth in section 161.001(b)(1)(D) and (E) of the Family Code.

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

in the Interest of L.V.B.D., a Child · filed 2020-02-12(b)(1)(E)

The evidence of Mom’s drug use, domestic violence, incarceration, and choice of housing that would be unsafe for L.V.B.D. was factually sufficient to support the trial court’s finding under subsection 161.001(b)(1)(E) and its finding on best interest of the child.

Section 161.001(b)(1)(D) and (E) provide grounds for termination when a parent endangers a child through the child’s surroundings or the parent’s conduct.

in the Interest of M. A. C., a Child · filed 2020-02-12(b)(1)(D), (b)(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to support termination of M.A.C.’s parental rights under subsections (D) and (E) of Texas Family Code Section 161.001(b).

Section 161.001(b)(1)(D) and (E) permit endangerment findings when parental conduct jeopardizes a child’s physical or emotional well-being, even if that child suffers no physical injury.

in the Interest of A.E.J. and V.N.J., Minor Children · filed 2020-02-13(b)(1)(D), (b)(1)(E)

This case concerns only appellants’ parental rights to A.E.J. and V.N.J., and the evidence in this case does not show that those children in particular suffered any physical injury due to E.J.’s conduct or neglect. However, such a showing is not necessary to support endangerment findings with respect to A.E.J. and V.N.J.

Section 161.001(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 J.Z.S., a Child · filed 2020-02-20(b)(1)(E)

Under the applicable standards of review, we conclude the evidence is legally and factually sufficient to support the trial court’s finding that Mother ... endangered John as described in 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.

in the Interest of B.G.R. · filed 2020-03-03(b)(1)(E)

We hold the evidence of H.C. III’s involvement with illegal drugs, his imprisonment, his conduct with respect to A.C., his role in assisting S.R. to hide from the Department instead of helping her to obtain substance abuse treatment, and his abandonment of B.G.R. is both legally and factually sufficient to support the trial court’s finding that H.C. III engaged in conduct that endangered B.G.R.’s 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.

W. L. v. Texas Department of Family and Protective Services · filed 2020-03-12(b)(1)(E)

After carefully reviewing the record, we conclude that the evidence was legally and factually sufficient to support the trial court’s finding that W.L. engaged in conduct which endangered the physical or emotional well-being of her children.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child; methamphetamine use and domestic violence can support that finding.

in the Interest of A.H., S.C., and C.M., Children · filed 2020-03-19(b)(1)(E)

Based upon evidence that the parents engaged in domestic violence in the children’s presence and that the parents used methamphetamine while the children were in their care, the trial court could have found by clear and convincing evidence that the mother and the father engaged in a course of conduct that endangered the children. We hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to the mother and the father under subsection (E).

Subsection (b)(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 J.F.-G., a Child · filed 2020-03-23(b)(1)(E)

A review of the record reflects that the evidence was legally and factually sufficient to support the trial court’s determination that Father engaged in conduct described in subsection (E).

Section 161.001(b)(1)(D) and (E) permit termination on clear and convincing evidence that a parent endangered a child through unsafe conditions or a course of conduct.

in the Interest of P.M. · filed 2020-02-20(b)(1)(D), (E)

Having concluded that the evidence is legally and factually sufficient to support the trial court’s findings of endangerment under subsections D and E as to both Mother and Father, we overrule Mother’s and Father’s issues.

Section 161.001(b)(1)(D) and (E) allow termination based on endangering surroundings or a parent's endangering course of conduct.

in the Interest of A.B., G.B., L.B., S.B., and K.B., Children · filed 2020-02-27(b)(1)(D), (E)

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

Section 161.001(b)(1)(D) permits termination for knowingly exposing a child to endangering surroundings, while subsection (E) addresses a parent’s endangering course of conduct.

in the Interest of B.T.K., a Child · filed 2020-02-26(b)(1)(D), (b)(1)(E)

Further, after considering the entire record, including any disputed or contrary evidence, we conclude the evidence is factually sufficient to support the trial court’s termination findings under Sections 161.001(b)(1)(D) and (E).

Section 161.001(b)(1)(D) and (E) permit termination when a parent's single act of arson endangers a child.

in the Interest of L. D. C., a Child · filed 2020-02-26(b)(1)(D), (b)(1)(E)

Setting fire to a house in which L.D.C. was sleeping is an act of arson, standing alone, is enough to justify termination under either Subsection D or Subsection E.

Subsection (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.

E. E. and C. C. v. Texas Department of Family and Protective Services · filed 2020-02-28(b)(1)(E)

On this record, we conclude that the evidence is sufficient to support the district court’s finding under subsection (E) that the father engaged in conduct that endangered the child.

Section 161.001(b)(1)(D) requires sufficient evidence that a parent knowingly placed or kept a child in endangering surroundings; under (b)(1)(E), repeated illegal drug use during a termination case can support an endangering course of conduct.

in Re D.C., J.C. III, J.C., and J.C. · filed 2020-03-04(b)(1)(D), (b)(1)(E)

For all these reasons, we conclude that the evidence supporting the jury’s § 161.001(b)(1)(D) finding is legally insufficient. ... Under In re C.V.L., the evidence is legally sufficient to support the jury’s § 161.001(b)(1)(E) finding.

Subsections (b)(1)(D) and (E) permit termination when a parent’s conduct or the child’s surroundings endanger the child’s physical or emotional well-being.

in the Interest of B.B., a Child · filed 2020-03-05(b)(1)(D), (b)(1)(E)

In sum, the evidence shows that Mother exposed the children to drug abuse, did not maintain her emotional stability by taking her prescription medications consistently and did not give the children a stable, safe home to live in. Mother physically injured Brad and had “go[ne] too far” in disciplining him before. She failed to take the actions that would have protected the children from sexual abuse and to the extent that she told the truth about having previously seen the bruising on Brad’s penis, did nothing to remove them from the danger after she saw evidence of it. Applying the appropriate standards of review, we hold that the evidence is legally and factually sufficient to support the trial court’s endangerment findings.

Subsections (b)(1)(D) and (E) allow termination based on a parent’s knowing exposure of a child to dangerous conditions or conduct endangering the child’s physical or emotional health.

A. J. R. v. Texas Department of Family and Protective Services · filed 2020-03-12(b)(1)(D), (E)

The evidence is therefore both legally and factually sufficient to support the district court’s conclusions with respect to Emma and Hayden under subsections (D) and (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.

in the Interest of J.S. and B.R., Children · filed 2020-04-09(b)(1)(E)

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows that the parent has engaged in conduct or knowingly placed the child with persons who engaged in conduct which endangers the child’s physical or emotional well-being. ... Specifically, we conclude the trial court’s findings with respect to subsections (E) and (N) and its finding with respect to the best interest of J.S. and B.R. were supported by the evidence.

Termination under subsection (b)(1)(E) requires a voluntary, deliberate, and conscious course of conduct by the parent; a single act or omission is insufficient.

in the Interest of J.A. & N.A., Children · filed 2020-04-28(b)(1)(E)

However, termination under subsection (E) must be based on a voluntary, deliberate, and conscious course of conduct by the parent; a single act or omission is not enough.

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

in the Interest of E.C., a Child · filed 2020-04-30(b)(1)(E)

We hold that the evidence, viewed in the appropriate deferential light, was factually sufficient to reasonably form a firm conviction or belief to support the finding that Mother had engaged in conduct or had knowingly placed Evan with persons who had engaged in conduct that had endangered Evan’s physical or emotional well-being.