Tex. Fam. Code Ann. § 161.001

Repeated criminal conduct and incarceration can support termination when the resulting instability endangers a child’s physical or emotional well-being.

J. B., Jr. and Y. R. v. Texas Department of Family and Protective Services · filed 2020-05-06(b)(1)(E)

On this record, we conclude that the evidence is legally sufficient to support the trial court’s finding under subsection (E) that Father engaged in conduct that endangered the children.

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

in the Interest of B.S. and J.M., Children · filed 2020-08-10(b)(1)(E)

Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s conclusions that appellant’s parental rights to A.D., B.S., and J.M. should be terminated under subsection 161.001(b)(1)(E).

Subsection (b)(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being; drug use and incarceration may support that finding.

in the Interest of P.M.M.K. · filed 2020-04-08(b)(1)(E)

On this record, we hold that the evidence is legally and factually sufficient to support the trial court’s finding under section 161.001(b)(1)(E) of the Family Code.

Under subsection (b)(1)(E), a parent’s course of conduct can endanger children through domestic violence, methamphetamine use, and exposure to illegal drugs.

in the Interest of J.M.S., J.M.P.S., and A.M.K.S., Children · filed 2020-04-16(b)(1)(E)

We hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to the mother under subsection (E).

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

in the Interest of K.W. and T.W. · filed 2020-04-09(b)(1)(D), (E)

The evidence was legally and factually sufficient to show that Mother endangered the minor children’s “physical and emotional well-being” as required under subsections 161.001(b)(1)(D) and (E).

Subsection (b)(1)(E) permits termination when a parent’s endangering conduct is directed at another person in the child’s household.

E. D. v. Texas Department of Family and Protective Services · filed 2020-04-17(b)(1)(E)

But that difference does not change our conclusion: a parent’s rights to her child may be terminated even if the conduct made the subject of a subsection (E) allegation was directed at another person in the household.

Section 161.001(b)(1)(D) and (E) make endangerment through a child’s surroundings or a parent’s conduct grounds for terminating parental rights.

in the Interest of J.T., Child v. Department of Family and Protective Services · filed 2020-04-23(b)(1)(D), (E)

Based on this record, we conclude that there is legally and factually sufficient evidence of endangerment to satisfy subsections 161.001(b)(1)(D) and (E).

Section 161.001(b)(1)(D) and (E) provide grounds for termination based on endangering surroundings and endangering conduct, respectively.

in the Interest of M.K., a Child · filed 2020-04-23(b)(1)(D), (E)

We hold that the evidence suffices both legally and factually to support the findings that Charles • knowingly placed or knowingly allowed Mary to remain in conditions or surroundings that endangered her physical or emotional well-being and • engaged in conduct or knowingly placed Mary with persons who engaged in conduct that endangered Mary’s physical or emotional well-being.

Subsection (b)(1)(D) addresses an environment that endangers a child, while subsection (b)(1)(E) addresses endangerment caused by a parent’s course of conduct.

in the Interest of A.S. and S.S., Children · filed 2020-04-30(b)(1)(D), (E)

Considering the evidence in the light most favorable to the trial court’s findings and considering the record as a whole, the evidence is sufficient to support the Subsection (D) and (E) endangerment findings. We therefore overrule Father’s first and second issues.

Section 161.001(b)(1)(D) covers a child’s endangering surroundings, while subsection (E) covers a parent’s endangering course of conduct; continued drug use can support findings under both grounds.

in the Interest of B.L.H., a Child · filed 2020-08-18(b)(1)(D), (E)

Because we find the evidence sufficient to support the trial court’s Grounds D and E findings, we overrule Krystal’s first point of error.

Section 161.001(b)(1)(E) permits termination when a parent’s conscious course of conduct endangers a child, including by repeatedly returning to a relationship involving domestic violence, substance abuse, and unstable housing.

in the Interest of L.P and C.P. · filed 2020-08-26(b)(1)(E)

We conclude the evidence supports the trial court’s finding that Mother engaged in a conscious course of conduct that endangered the children by staying in and/or repeatedly returning to a relationship with Father that involved domestic violence, on-going substance abuse by Father, and unstable housing. We therefore hold the evidence is both legally and factually sufficient to support the trial court’s endangerment finding under subsection (E) as to Mother.

Under Section 161.001, a parent’s awareness and disregard of a potential danger of abuse can establish endangerment without proof that the parent knew abuse was occurring.

B. D. and S. P. D. v. Texas Department of Family and Protective Services · filed 2020-08-28(b)(D), (b)(E)

The Department did not have to establish that Mother had actual knowledge that Father was abusing Karla and Lisa; it could satisfy its burden by showing that Mother was aware of the potential danger of abuse and disregarded it.

Section 161.001(b)(1)(E) permits termination when a parent’s harmful conduct toward one child endangers another child at risk of the same conduct.

in the Interest of A.E.J., L.S.J., and D.M.J., Children · filed 2020-08-31(b)(1)(E)

Indeed, predatory or harmful conduct directed at one child will support termination of parental rights as to a different child, because all children at risk for the same conduct by the same predator are endangered.

Subsection (b)(1)(E) allows termination when clear and convincing evidence shows that a parent’s conduct endangered the child’s well-being.

in the Interest of A.Q., a Child · filed 2020-09-17(b)(1)(E)

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 course of conduct endangers a child, including drug use combined with criminal conduct and incarceration.

in the Interest of M.J., a Child v. Texas Department of Family and Protective Services · filed 2020-12-01(b)(1)(E)

Mother’s drug use before and after pregnancy, combined with her substantial criminal history, leads us to conclude that sufficient evidence supports the 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 well-being; drug use during pregnancy and after removal can support that finding.

in the Interest of A.R., a Child · filed 2020-12-10(b)(1)(E)

Based upon evidence of Appellant’s use of methamphetamine and marihuana while pregnant with A.R., A.R.’s positive drug test results shortly after birth, and Appellant’s continued use of drugs after removal, the trial court could have found by clear and convincing evidence that Appellant had engaged in a course of conduct that endangered A.R. We hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to Appellant under subsection (E).

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

in the Interest of G.O., P.O., and L.O., Children · filed 2020-12-16(b)(1)(E)

We find that the evidence is legally and factually sufficient to support the trial court’s findings that Emily engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangers the children. TEX. FAM. CODE ANN. § 161.001 (b) (1) (E) (West Supp. 2019).

Section 161.001(b)(1)(E) allows termination when a parent’s conduct, or the conduct of someone with whom the parent knowingly leaves the child, endangers the child’s physical or emotional well-being; actual injury is unnecessary.

in the Interest of N.J.L., a Child · filed 2020-12-30(b)(1)(E)

Under subsection (E) it can be either the parent’s conduct or the conduct of a person with whom the parent knowingly leaves the child that endangers the physical or emotional well-being of the child. In either instance it is thus the direct result of the parent’s conduct that results in the termination of the parental rights. It is not necessary, however, that the conduct be directed at the child or that the child actually suffer injury.

Section 161.001(b)(1)(E) treats a parent’s course of drug use and criminal conduct that exposes a child to instability as endangerment of the child’s physical or emotional well-being.

in the Interest of J-R.A.M., a Child · filed 2020-12-30(b)(1)(E)

We find that the evidence is legally and factually sufficient to support the trial court’s findings that Robert engaged in conduct that endangered the child’s physical or emotional well-being. See TEX. FAM. CODE ANN. § 161.001(b)(1)(E).

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct, including drug use during pregnancy, endangers the child.

in the Interest of J.W., a Child · filed 2020-09-11(b)(1)(E)

Based upon evidence of Appellant’s history of drug use and her use of methamphetamine and marihuana while pregnant with J.W., the trial court could have found by clear and convincing evidence that Appellant engaged in a course of conduct that endangered J.W. See id. We hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to Appellant 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, including through missed visits, unresolved anger, and continued illegal drug use.

D. L. G., Sr. and C. K. M. v. Texas Department of Family and Protective Services · filed 2020-11-19(b)(1)(E)

Considering all of 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 Father endangered the children by posing emotional risks to them and by generating instability and uncertainty in their lives, especially considering his months-long failure to attend visitations, failure to adequately address his violence and anger issues, and continuing illegal drug use. 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 conduct endangers a child’s physical or emotional well-being; continued drug use and unwillingness to seek help can support that finding.

in the Interest of B.C.A., a Child · filed 2021-01-06(b)(1)(E)

In this case, Father’s use of methamphetamine and his unwillingness to seek help for his drug use demonstrates an inability to provide for B.C.A.’s emotional and physical needs and to provide a stable environment for the child. ... Our independent review supports termination under subsection (E).

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

in the Interest of T.E.C., Children v. . · filed 2021-01-06(b)(1)(E)

We therefore hold the evidence is both legally and factually sufficient to support the trial court’s endangerment findings under subsection (E) as to both Mother and Father.

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

in the Interest of A.L., a Child · filed 2020-09-17(b)(1)(E)

Based upon evidence of Appellant’s use of methamphetamine while responsible for the care of A.L.; A.L. testing positive for methamphetamine at a level of 10,370 pg/mg, amphetamine at 517 pg/mg, and marihuana at 0.2 pg/mg; Appellant’s continued use of drugs after removal; and the existence of domestic violence between the parents, the trial court could have found by clear and convincing evidence that Appellant engaged in a course of conduct that endangered A.L.

Domestic violence, drug use, and exposing children to sexual acts can establish the endangering course of conduct required by Section 161.001(b)(1)(E).

in the Interest of L.W. and M.W., Children · filed 2021-01-14(b)(1)(E)

Here, based upon evidence of domestic violence between Appellant and the children’s father while the children were in their care, Appellant’s use of methamphetamine and marihuana while the children were in her care, Appellant’s continued use of drugs after removal, and Appellant’s apparent exposure of the children to sexual acts between the parents, the trial court could have reasonably found by clear and convincing evidence that Appellant had engaged in a course of conduct that endangered her children. Therefore, we hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to Appellant under subsection (E).

Section 161.001(b)(1)(E) requires evidence that the parent’s conduct endangered the child’s physical or emotional well-being.

in the Interest of M.D., a Child v. Texas Department of Family and Protective Services · filed 2020-09-21(b)(1)(E)

We sustain Father’s first issue to the extent he argues that the evidence is legally insufficient to support the jury’s finding under section 161.001(b)(1)(E).

Section 161.001(b)(1)(D) permits termination for knowingly placing a child in an endangering environment, while subsection (E) covers a parent’s endangering course of conduct.

in the Interest of J.S. and K.H., Children · filed 2020-09-30(b)(1)(D), (E)

Based on the fact that “illegal drug use by a parent . . . supports the conclusion that the child[]’s surroundings endanger their physical or emotional well-being,” we find the evidence legally and factually sufficient to support the trial court’s Ground D finding. ... Considering these facts, in addition to those discussed in our Ground D analysis, we find the evidence legally and factually sufficient to show that Father engaged in conduct that endangered K.H.’s physical well-being.

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

in the Interest of S.R.L., a Child · filed 2020-10-05(b)(1)(D), (E)

Therefore, the evidence was legally and factually sufficient to support the jury’s findings under paragraph (D). ... Accordingly, the evidence is legally and factually sufficient to support the jury’s finding concerning paragraph (E) of section 161.001(b)(1).

Section 161.001(b)(1)(D) and (E) allow termination when clear and convincing evidence establishes an endangering environment or endangering parental conduct.

in the Interest of M.S. and S.S., Children · filed 2020-10-15(b)(1)(D), (E)

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

Section 161.001(b)(1)(D) and (E) permit termination when a parent knowingly places a child in endangering surroundings or engages in conduct that endangers the child.

in the Interest of N.W.G. & L.S., Children · filed 2020-10-28(b)(1)(D), (E)

We find that the evidence is legally and factually sufficient to support the trial court’s findings that Haley knowingly placed or knowingly allowed the children to remain in conditions or surroundings that endanger the children, and engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangers the children.

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

in the Interest of R.G.F. · filed 2020-10-28(b)(1)(E)

Such conduct exposes a child to injury and poses a risk to the well-being of a child, even if the past conduct did not occur in the child’s presence.

Subsections (b)(1)(D) and (E) allow termination when clear and convincing evidence establishes that a parent exposed a child to endangering conditions or engaged in endangering conduct.

in the Interest of T.B., K.B., J.H., and J.H. · filed 2020-11-19(b)(1)(D), (E)

Deferring to the trial court’s credibility determinations and reviewing all the evidence in the light most favorable to the termination findings under subsections D and E, the trial court could reasonably have formed a firm belief or conviction that Trish and Josh, through their individual acts or omissions or a course of conduct, endangered the children’s physical or emotional well-being. We conclude the Department established, by clear and convincing evidence, that Trish and Josh committed the predicate acts enumerated in subsections D and E.

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

in the Interest of A.W., A.W., and A.W., Children v. Texas Department of Family and Protective Services · filed 2020-12-03(b)(1)(E)

Accordingly, the evidence is legally and factually sufficient to support termination of parental rights under predicate ground E.

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 surroundings or engaged in conduct that endangered the child.

in the Interest of D.B and K.B., Children · filed 2020-12-10(b)(1)(D), (E)

Having examined the entire record, we find that the trial court could reasonably form a firm belief or conviction that Father knowingly placed or knowingly allowed D.B. and K.B. to remain in conditions or surroundings which endangered their physical or emotional well-being and engaged in conduct which endangered D.B. and K.B.’s physical and emotional well-being. The same evidence is factually sufficient to support the trial court’s affirmative finding.

Section 161.001(b)(1)(E) requires a causal connection between a parent’s drug use and endangerment of the child.

in the Interest of Z.A.R. A/K/A Z.R., a Child v. Texas Department of Family and Protective Services · filed 2020-12-31(b)(1)(E)

This case is distinguishable from L.C.L. in that there is evidence of a causal connection between Mother’s drug use and endangerment of Bobby.

Section 161.001(b)(1)(E) does not treat missed visits caused by pandemic restrictions and lack of access to virtual visit technology as evidence of endangerment.

in the Interest of J. A. v. a Child · filed 2021-01-29(b)(1)(E)

We hold that, on this record, Mother and Father’s inability to participate in visits during March and April due to social distancing restrictions and lack of access to technology that would allow virtual visits constitutes no evidence in support of termination.

Section 161.001(b)(1)(E) permits termination, with a best-interest finding, 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 D.F.S., C.S.S., and C.R.S., Children · filed 2021-02-17(b)(1)(E)

Thus, we hold the evidence is legally sufficient to support the trial court’s finding under subsection (E) for each parent.

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

in the Interest of J.P., J.S.P., and A.P., Children · filed 2021-03-09(b)(1)(E)

Here, based upon evidence of domestic violence committed by the father against the mother while the children were in their care, the father’s extensive criminal history, and the use of drugs in the children’s presence, the trial court could have reasonably found by clear and convincing evidence that the father had engaged in a course of conduct that endangered his children or that he had knowingly placed the children with persons who engaged in conduct that endangered the children’s physical or emotional well-being. Therefore, we hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to the father under subsection (E).

Subsection (b)(1)(E) permits termination when a parent’s course of conduct endangers a child; abuse and neglect can establish endangerment even if a particular injury was unintended.

M. J. v. Texas Department of Family and Protective Services · filed 2021-03-19(b)(1)(E)

On this record, taking into account all the evidence before the district court, we cannot say that no reasonable factfinder could have formed a firm belief or conviction that Mother engaged in conduct that endangered A.J.’s physical and emotional well-being. The evidence is therefore both legally and factually sufficient to support the district court’s finding under Subsection (E).

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

in the Interest of S.N.D. and L.E.D., Children · filed 2021-03-31(b)(1)(E)

Based upon evidence of Appellant’s use of methamphetamine while she was pregnant with L.E.D. and Appellant’s continued use of methamphetamine thereafter, the trial court could have found by clear and convincing evidence that Appellant had engaged in a course of conduct that endangered her children. We hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to Appellant 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.

M. B. and O. R., Jr. v. Texas Department of Family and Protective Services · filed 2021-04-14(b)(1)(E)

The evidence is legally and factually sufficient to support the trial court’s finding that Mother engaged in 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 engaged in conduct endangering a child’s physical or emotional well-being.

in the Interest of E.M. · filed 2021-04-15(b)(1)(E)

Viewing all the evidence in the light most favorable to the trial court’s finding, we conclude that a reasonable trier of fact could have formed a firm belief or conviction that Mother knowingly engaged in conduct which endangers the physical or emotional well-being of the child.

Section 161.001(b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent knowingly exposed a child to an endangering environment or engaged in a course of conduct that endangered the child.

in the Interest of N.P. · filed 2021-01-21(b)(1)(D), (E)

We conclude the evidence was legally and factually sufficient to support the trial court’s endangerment findings under subsections D and E.

Subsections (b)(1)(D) and (E) permit termination when clear and convincing evidence establishes endangering surroundings or conduct and termination is in the child’s best interest.

in the Interest of L.A.C., A.I.A.C, S.A.C., H.A.C. · filed 2021-02-03(b)(1)(D), (E)

The evidence of Mom’s drug use, domestic violence relationships, and inability to pursue her children’s best interests, for example, by taking them to school, was sufficient to support the trial court’s findings under subsection 161.001(b)(1)(D) and (E) and its findings on best interests of the children.

Section 161.001(b)(1)(D) and (E) permit termination when a parent exposes children to an endangering environment or engages in an endangering course of conduct.

in the Interest of Y.Z., N.A.Z., J.F.Z., and V.V.Z., Children · filed 2021-02-10(b)(1)(D), (E)

This evidence supports a conclusion that Mother’s drug abuse led to neglectful supervision and care for the children which resulted in a course of conduct and an environment that endangered the children.

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 them.

in the Interest of C.N.L., P.A.L., D.J.L., D.D.L., B.M.L., J.J.L., and J.J.L., Children · filed 2021-02-18(b)(1)(D), (b)(1)(E)

We conclude that, from the evidence set forth, a rational trier of fact could have formed a firm belief or conviction that both appellants (1) knowingly placed the children or allowed the children to remain in an endangering environment, and (2) engaged in conduct which endangered the children or knowingly placed the children with persons who engaged in such conduct. See TEX. FAM. CODE ANN. § 161.001(b)(1)(D), (E).

Subsections (b)(1)(D) and (E) allow termination based on a child’s endangering surroundings or a parent’s course of endangering conduct.

C. A. C. v. Texas Department of Family and Protective Services · filed 2021-03-02(b)(1)(D), (E)

After carefully reviewing the record, we conclude that the evidence was legally and factually sufficient to support the trial court’s findings under subsections (D) and (E).

Section 161.001(b)(1)(D) permits termination for endangering conditions, while subsection (E) permits termination for a course of conduct that endangers a child’s physical or emotional well-being.

in the Interest of C.F. · filed 2021-03-18(b)(1)(D), (b)(1)(E)

We conclude the Department established, by clear and convincing evidence, that Erica committed the predicate acts enumerated in subsections D and E.

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

in the Interest of M.H., M.H., and N. H. · filed 2021-04-01(b)(1)(D), (E)

First, we conclude the record contains clear and convincing evidence sufficient to show that Mother knowingly allowed the children to remain in conditions that endangered them. Second, we conclude the record contains clear and convincing evidence sufficient to prove that Mother engaged in conduct dangerous to the physical or emotional well-being of her children.

Section 161.001(b)(1)(D) and (E) allow termination when clear and convincing evidence shows endangering surroundings or a parent’s endangering course of conduct, including persistent drug use and domestic violence.

in the Interest of J.S., a Child · filed 2021-04-07(b)(1)(D), (E)

Considering the entire record, we conclude that the evidence is both legally and factually sufficient to support termination under grounds D and 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 J.B., a Child v. Texas Department of Family and Protective Services · filed 2021-04-29(b)(1)(E)

Further, in view of the entire record, we conclude the 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).

Missed NICU visits and failure to learn to use a child’s feeding tube, standing alone, do not establish endangering conduct under subsection (b)(1)(E).

M. D., Jr. and C. A. v. Texas Department of Family and Protective Services · filed 2021-04-30(b)(1)(E)

While we agree that the trial court, as the trier of fact, could have reasonably inferred from the evidence before it that Mother and Father failed, without a sufficiently valid reason, to regularly visit the neonatal unit and that they failed to learn how to insert and maintain the NG tube, we disagree that this conduct, standing alone, supports termination under subsection (E).

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

in the Interest of E.R.G. and J.R.J., Children · filed 2021-05-06(b)(1)(E)

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

Section 161.001(b)(1)(E) does not require proof that a parent knowingly engaged in endangering conduct.

in the Interest of R.H., F v. M v. and P.H., Children · filed 2021-05-20(b)(1)(E)

But the statute’s plain language does not require that a parent knowingly engage in endangering conduct.

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 H.H. & C.H., Children · filed 2021-05-27(b)(1)(E)

We find that, while the Department could have presented more evidence regarding these issues, the evidence was still legally and factually sufficient for the trial court to have found that Amanda "engaged in conduct … which endanger[ed] the physical or emotional well-being of the child[ren]." TEX. FAM. CODE ANN. § 161.001(b)(1)(E).

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

in the Interest of J.R.R. and R.N.R., Children · filed 2021-05-28(b)(1)(E)

Here, based upon evidence of Appellant’s use of drugs (including methamphetamine) while the children were in her care, Appellant’s continued use of methamphetamine thereafter, Appellant’s threats to kill the father while he had custody of R.N.R., and Appellant’s unresolved mental health issues, the trial court could have reasonably found by clear and convincing evidence that Appellant had engaged in a course of conduct that endangered her children. Therefore, we hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to Appellant under subsection (E).

Subsection (b)(1)(E) permits termination when a parent's course of conduct endangers a child's physical or emotional well-being; repeated criminal conduct and imprisonment can support an endangerment finding.

E. N. v. Texas Department of Family and Protective Services · filed 2021-06-17(b)(1)(E)

Reviewing the record under the applicable standard, we conclude that legally sufficient evidence supports the jury’s finding that Father engaged in a course of conduct that endangered Charles’s well-being.

Section 161.001(b)(1)(D) and (E) permits termination when clear and convincing evidence shows that a child was endangered by the child's surroundings or the parent's conduct.

in the Interest of D. J. W., a Child · filed 2021-04-19(b)(1)(D), (b)(1)(E)

Based on the state of the evidence taken as a whole, we find that the Department established the existence of Subsection (D) and (E) endangerment predicate grounds by clear and convincing evidence.

Section 161.001(b)(1)(D) and (E) allow termination when a parent knowingly places or allows a child in endangering conditions or engages in conduct that endangers the child.

in the Interest of D.B.S., B.L.S., B.L.P., D.E.S., and A.B.P., Children · filed 2021-04-26(b)(1)(D), (E)

Because the evidence is legally and factually sufficient to support the endangerment findings, we need not address the finding on subsection (O).

Section 161.001(b)(1)(D) and (E) provide grounds for terminating parental rights when clear and convincing evidence shows that a parent knowingly kept a child in endangering conditions or engaged in conduct that endangered the child.

in the Interest of R.H., Z.K., K.K., and L.K., Children · filed 2021-04-30(b)(1)(D), (E)

Accordingly, we find that the evidence was legally and factually sufficient to support termination of S.K.’s parental rights under subsections D and E of Section 161.001 of the Texas Family Code.

Section 161.001(b)(1)(D) and (E) establish termination grounds based on endangering conditions or surroundings and endangering parental conduct, respectively.

in the Interest of E. S., a Child · filed 2021-06-17(b)(1)(D), (b)(1)(E)

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

Section 161.001(b)(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 B.P. Jr. · filed 2021-06-24(b)(1)(D), (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 M.P. knowingly placed or knowingly allowed B.P. Jr. to remain in conditions or surroundings which endangered his physical or emotional well-being and engaged in conduct or knowingly placed B.P. Jr. with persons who engaged in conduct that endangered B.P. Jr.’s physical or emotional well-being.

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

in the Interest of S.B. and K.B., Children · filed 2021-05-14(b)(1)(D), (E)

Therefore, we conclude the evidence is legally and factually sufficient to support the trial court’s findings pursuant to Section 161.001(b)(1)(D) and (E).

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 D.C.M.F., a Child · filed 2021-05-28(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)(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 J.S. · filed 2021-06-10(b)(1)(D), (E)

We conclude the Department established, by clear and convincing evidence, that Vivian committed the predicate acts enumerated in subsections D and E.

Section 161.001(b)(1)(D) and (E) permit termination when a child’s surroundings or a parent’s conduct endangers the child’s physical or emotional well-being.

in the Interest of A.L.G., C.C.A., and A.R.A., Children · filed 2021-06-17(b)(1)(D), (E)

Our independent review supports termination under subsections (D) and (E).

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 surroundings or engaged in endangering conduct.

in the Interest of R. S., Jr. · filed 2021-06-30(b)(1)(D), (E)

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

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.

C. C. v. Texas Department of Family and Protective Services · filed 2021-07-21(b)(1)(E)

As for statutory-predicate grounds supporting termination of parental rights, our review of the record leads us to conclude that the evidence was legally and factually sufficient to support the trial court’s finding that Mother 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. See Tex. Fam. Code § 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; the father’s criminal activity, drug use, and the child’s exposure to methamphetamine supported termination under this ground.

in the Interest of A.W., a Child · filed 2021-07-29(b)(1)(E)

Father’s arrest (and subsequent conviction and incarceration) and Amanda’s testing positive for methamphetamine immediately thereafter supported Mother’s testimony about his drug use and criminal activity and showed that he had engaged in conduct that endangered Amanda’s physical and emotional well-being.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child; drug abuse, domestic violence, and inconsistent contact may together establish endangerment.

S. R. v. Texas Department of Family and Protective Services · filed 2021-08-06(b)(1)(E)

The trial court could have determined that given the evidence of domestic violence between Mother and Father, their ongoing relationship, Mother’s abuse of a serious drug before and during the case, and her failure to maintain contact with C.R., Mother had engaged in a course of conduct that endangered C.R.

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

in the Interest of M.W., a Child · filed 2021-08-19(b)(1)(E)

We conclude this evidence was legally and factually sufficient to support the trial court’s finding that Mother engaged in endangering conduct, violating 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; drug use accompanied by a child's exposure to methamphetamine can support that finding.

in the Interest of K.H. and J.W., Children · filed 2021-09-08(b)(1)(E)

The trial court was free to believe or disbelieve the testimony of Julie, a long-time drug user whose testimony was at times inconsistent with other testimony, and to believe the testimony of the Department and the caregiver, including the statements made by K.H., taken with the testimony that J.W. tested positive for methamphetamine at the time of his removal and was believed to have suffered from the long-term exposure to methamphetamine support the finding that Julie "engaged in conduct or knowingly placed the child[ren] with persons who engaged in conduct which endangers the physical or emotional well-being of the child[ren]." TEX. FAM. CODE § 161.001(b)(1)(E). We overrule issue two as to Section 161.001(b)(1)(E).

Section 161.001(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 L.J.H., a Child · filed 2021-09-20(b)(1)(E)

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

Subsection (b)(1)(E) permits termination when a parent’s course of conduct endangers a child; cocaine use during pregnancy and while caring for the child can satisfy that ground.

in the Interest of D.D.E., a Child · filed 2021-10-07(b)(1)(E)

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

Section 161.001(b)(1)(E) permits a court to consider endangering conduct that occurred after the child’s removal by the Department.

in the Interest of R.B., a Child · filed 2021-07-09(b)(1)(E)

Despite the generality of our statement in J.K.F., our own review in that case was consistent with the approach described by our sister court in S.R.—that is, while we did not explain that we could consider evidence after a child’s removal for subsection (E) purposes, we did, in fact, do so. ... We do so again here, at least with respect to subsection (E), and none of the parties have argued we may not do so.

Section 161.001(b)(1)(D) requires proof that a parent knowingly left children in endangering conditions; evidence that a mother knew her children were being starved and abused supported termination under subsections (D) and (E).

in the Interest of C.H. and B.C. · filed 2021-07-15(b)(1)(D), (E)

For these reasons, we reject Mother’s arguments that the trial court’s subsection D and E findings are supported by insufficient evidence.

A parent’s abuse of the other parent or neglect of another child can establish endangerment under subsection (b)(1)(E), even without conduct directed at the child.

in the Interest of A.G. and T.G., Children · filed 2021-07-21(b)(1)(E)

However, a parent’s abuse or neglect of the other parent or other children can support a finding of endangerment of a child who was not present or not even born at the time of the conduct. ... We conclude the trial court reasonably could have formed a firm belief or conviction about the truth of the State’s endangerment allegation, and the evidence is both legally and factually sufficient to support the court’s finding under section 161.001(b)(1)(E) of the Texas Family Code.

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

in the Interest of A.B., a Child · filed 2021-07-28(b)(1)(E)

We therefore hold legally and factually sufficient evidence supports the trial court’s finding that appellant violated section 161.001(b)(1)(E), and overrule his arguments to the contrary.

Section 161.001(b)(1)(E) permits termination when a parent’s abuse of one child endangers other children, even if they were not direct victims.

in the Interest of L.R and D.R., Children · filed 2021-07-29(b)(1)(E)

Acts of violence or abuse directed toward one child can endanger other children that are not the direct victims of the conduct and support termination of parental rights of the other children.

Subsections (D) and (E) make endangering surroundings and a parent’s endangering course of conduct grounds for termination when proved by clear and convincing evidence.

S. B. v. Texas Department of Family and Protective Services · filed 2021-08-25(b)(1)(D), (E)

We hold that the Department presented clear and convincing evidence from which the trial court could have concluded that Mother engaged in a course of conduct that endangered the children’s well-being and that she placed them in circumstances or surroundings that endangered their well-being.

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

in the Interest of T.M., M.M., and N.M., Children · filed 2021-09-02(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. ... We hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to Appellant under subsection (E).

Section 161.001(b)(1)(D) and (E) allow termination based on endangering surroundings or conduct when the grounds are proved by clear and convincing evidence and termination is in the child’s best interest.

in the Interest of E.F., a Child · filed 2021-09-09(b)(1)(D)–(E)

Based on our review of the record, including Father and Mother’s history as well as the July 5, 2019 events, we hold that the Department presented legally and factually sufficient evidence to support the trial court’s subsection (D) and (E) endangerment findings.

Subsection (D) permits termination for knowingly exposing a child to endangering surroundings, while subsection (E) permits termination for a parent's endangering course of conduct.

in the Interest of O.G.H.D. · filed 2021-09-30(b)(1)(D), (E)

We conclude that the Department established, by clear and convincing evidence, that Chase committed the predicate acts enumerated in subsections D and E.

Subsections (b)(1)(D) and (E) require proof of endangerment, but neither requires proof that the child suffered an actual injury.

in the Interest of A.Q.H. IV · filed 2021-09-30(b)(1)(D), (b)(1)(E)

Both subsections require proof of endangerment. That said, neither subsection required the Department to prove that Mother’s conduct resulted in any actual injury to Adrian or to another child.

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

in the Interest of L.L.L., a Child · filed 2021-10-06(b)(1)(E)

The evidence is legally and factually sufficient to support the trial court’s determination that Father violated § 161.001(b)(1)(E).

Subsection (E) requires evidence of a voluntary, deliberate, and conscious course of conduct that endangers a child.

T. M. and O. A. v. Texas Department of Family and Protective Services · filed 2021-10-08(b)(1)(E)

On this record, we conclude that the evidence is legally sufficient but factually insufficient to support the trial court’s finding that either Mother or Father engaged in a “voluntary, deliberate, and conscious course of conduct” that endangered the children’s physical or emotional well-being.

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

in the Interest of V.L.M., a Child · filed 2021-10-21(b)(1)(E)

Here, based upon evidence that Appellant was physically abusive to V.L.M. and had exposed V.L.M. to domestic violence as well as sexual acts between Appellant and Hernandez, the trial court could have reasonably found by clear and convincing evidence that Appellant had engaged in a course of conduct that endangered V.L.M. Therefore, we hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to Appellant 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 N.J., a Child · filed 2021-11-01(b)(1)(E)

Mother’s pervasive criminal conduct, her extensive drug use, and the totality of the evidence 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; ongoing drug use and failure to obtain medical care can support that finding.

D. H. v. Texas Department of Family and Protective Services · filed 2021-11-03(b)(1)(E)

Consequently, the evidence is legally and factually sufficient to support the district court’s finding that termination of Mother’s parental rights was warranted under subsection (E).

Section 161.001(b)(1)(E) allows 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 M.M. and E.L., Children · filed 2021-11-10(b)(1)(E)

We hold that the evidence is legally and factually sufficient to show that Mother engaged in a course of conduct that endangered her children’s physical or emotional well-being.

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; conduct after the child’s removal may be considered.

J. B. v. Texas Department of Family and Protective Services · filed 2021-11-17(b)(1)(E)

The evidence is legally and factually sufficient to show that Mother engaged in an endangering course of conduct. We thus affirm the trial court’s finding under subsection (E).

Subsection (b)(1)(E) permits termination when a parent’s pattern of abusive or violent conduct endangers a child, even if the conduct occurred before the child’s birth or was not directed at the child.

in the Interest of M.M.M. Child v. Department of Family and Protective Services · filed 2021-11-18(b)(1)(E)

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

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

in the Interest of M.R.H., a Child · filed 2021-12-01(b)(1)(E)

Based on the foregoing evidence, we conclude the evidence is sufficiently clear and convincing to support the trial court’s findings under section (b)(1)(E).

Methamphetamine use during pregnancy can constitute conduct that endangers a child under subsection (b)(1)(E).

A. A. v. Texas Department of Family and Protective Services · filed 2021-12-14(b)(1)(E)

The record here includes evidence of Mother’s use of methamphetamine, including while she was pregnant, which itself was endangering conduct, and testimony that her using that drug would mean that she could endanger Child.

Subsection (E) permits termination when a parent’s history of abusive and violent conduct clearly and convincingly establishes that the parent endangers the child’s physical or emotional well-being.

in the Interest of B.H. Child v. Department of Family and Protective Services · filed 2021-12-23(b)(1)(E)

Moore’s documented history of abusive and violent behavior provides clear and convincing evidence from which the trial court could have formed a firm conviction or belief that Moore has engaged in conduct that endangers Brooklyn’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, and continued illegal drug use can support that finding.

M. J. v. Texas Department of Family and Protective Services · filed 2022-01-05(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 Mother engaged in conduct that endangered the physical or emotional well-being of her children. See Tex. Fam. Code § 161.001(b)(1)(E); A.C., 560 S.W.3d at 630–31.

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 B.O. and M.M., Children · filed 2022-01-06(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. ... We hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to Appellant under subsection (E).

Section 161.001(b)(1)(E) allows an endangerment finding based on a parent’s drug use, failure to complete services, and prolonged failure to visit the children.

in the Interest of J.G., T.G., K.G., and L.G., Minor Children · filed 2022-01-20(b)(1)(E)

Father tested positive for illegal drugs in his April 2020 drug test, and he declined to take another test despite being ordered to do so. As noted above, his failure to test authorized the trial court to presume that if he had tested, the results would have been positive. See J.W., 2009 WL 806865, at *4. Father failed to complete most of the services in his service plan, and between May 2020 and the August 16, 2021 trial, he made almost no effort to attend visitations or check on his children’s well-being. The evidence was thus legally and factually sufficient to support an endangerment finding under Section 161.001(b)(1)(E).

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

in the Interest of J.K., J.K., and J.K., Children · filed 2021-11-04(b)(1)(E)

The trial court found a statutory ground for termination under subsection (E), which is satisfied where a parent has “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). ... Even under our heightened standard of review, the evidence is both legally and factually sufficient to support the trial court’s finding that Mother’s conduct endangered the children’s physical and emotional well-being.

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 E.A., D.R., Z.A., and A.R., Children · filed 2021-11-24(b)(1)(E)

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

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows that a parent’s conduct exposed the child to loss, injury, or jeopardy.

in the Interest of K.A., A.S.B. AKA A.A., Children · filed 2022-01-26(b)(1)(E)

The totality of evidence before the trial court was enough to allow the factfinder to form a clear and convincing belief that Mother’s conduct satisfied the elements of (E), at the very least. It showed that she engaged in conduct which exposed A.S.B. to loss, injury, or jeopardy.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child, including through drug use and exposure to domestic violence.

in the Interest of T.N.R., a Child v. Texas Department of Family and Protective Services · filed 2022-02-08(b)(1)(E)

As here, a parent’s abusing drugs and exposing a child to domestic violence can present an endangering course of conduct sufficient under subsection (E).

A parent’s conduct can support an endangering-conduct finding even while the child is in the Department’s custody.

in the Interest of C.Y., a Child · filed 2022-02-18(b)(1)(E)

Because such endangerment is a course of conduct, Mother need not have had Calvin in her custody for her behavior to constitute endangering conduct under the governing statute and applicable case law.

Subsection (b)(1)(E) requires evidence that a parent’s conduct directly endangered the child.

in the Interest of G.F., a Child · filed 2022-02-22(b)(1)(E)

Under Subsection 161.001(b)(1)(E), we ask whether evidence shows that the parent’s conduct directly resulted in the child’s endangerment.

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows that a parent’s course of conduct endangered a child.

in the Interest of J.L.R. and T.P.R., Children · filed 2022-02-24(b)(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to uphold the trial court’s finding of termination 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.

in the Interest of E.C. and A.O., Children · filed 2022-03-04(b)(1)(E)

Comparing this evidence to the authority just mentioned, we hold that the trial court could have reasonably formed a firm belief or conviction that the elements of § 161.001(b)(1)(E) were met.

Section 161.001(b)(1)(E) permits termination when a parent’s repeated failure to protect children from obvious abuse endangers them.

in the Interest of R.A.E. and J.D.F., Children · filed 2022-03-16(b)(1)(E)

Father disregarded the children’s safety when he chose to ignore the obvious signs of abuse and return the children to Mother’s abusive household, resulting in a repeated course of conduct that endangered the children.

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows a parent’s deliberate course of conduct endangers a child’s physical or emotional well-being; continued illegal drug use can satisfy this ground.

in the Interest of L.I.C.S., a Child · filed 2022-03-16(b)(1)(E)

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

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

in the Interest of J.M. and J.M., Children · filed 2022-03-24(b)(1)(E)

We hold that the evidence was legally and factually sufficient to enable the trial court to form a firm belief or conviction that Mother had engaged in conduct that endangered the children. We overrule Mother’s third issue. Having upheld the Subsection (E) ground, we do not address Mother’s second, fourth, and fifth issues challenging the Subsection (D), (N), and (O) grounds.

Repeated domestic violence against a pregnant mother can establish a course of conduct endangering the child under subsection (b)(1)(E).

R.G. v. Department of Family and Protective Services · filed 2022-03-29(b)(1)(E)

Kyle’s exposure to this violence, in utero, constituted evidence of endangerment.

A parent’s course of violence, incarceration, inability to provide financial support, and illegal drug use can establish endangering conduct under subsection (b)(1)(E).

in the Interest of A.S., a Child · filed 2022-04-06(b)(1)(E)

Father exhibited a course of conduct that endangered A.S.’s physical and emotional well-being due to Father’s violence against Mother, his incarceration, his inability to provide financial support, and his continuing use of illegal drugs.

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.A.W., a Child · filed 2022-04-22(b)(1)(E)

Based on this record, we find that legally and factually sufficient evidence supported the trial court’s finding under ground E.

Subsection (b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being; repeated missed drug tests and visits can support that finding.

in the Interest of J.C.N., Children · filed 2022-04-29(b)(1)(E)

Applying the appropriate standards of review, we conclude the evidence is legally and factually sufficient to support the trial court’s finding that Mother engaged in conduct which endangered the physical or emotional well-being of the Children.

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

in the Interest of A.B.M., a Child · filed 2022-05-03(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 subsection 161.001(b)(1)(E).

Subsection (b)(1)(E) permits termination when a parent’s conduct or knowing placement of a child with another person endangers the child’s physical or emotional well-being.

in the Interest of O.O. Jr., a Child · filed 2022-05-05(b)(1)(E)

We also conclude that, based on the entire record, a factfinder could reasonably form a firm conviction or belief that Mother engaged in conduct or knowingly placed O.O. with persons who engaged in conduct which endangered his physical or emotional well-being.

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

in the Interest of O.O. Jr., a Child · filed 2022-05-17(b)(1)(E)

We conclude there is clear and convincing evidence to support termination under § 161.001(b)(1)(E). See TEX. FAM. CODE ANN. § 161.001(b)(1)(E). We also conclude that, based on the entire record, a factfinder could reasonably form a firm conviction or belief that Mother engaged in conduct or knowingly placed O.O. with persons who engaged in conduct which endangered his physical or emotional well-being.

Section 161.001(b)(1)(E) allows violence against a child’s other parent to support an endangerment finding even when the violence was not directed at the child.

in the Interest of B.E.S., a Child · filed 2022-04-27(b)(1)(E)

Although Dad’s alleged assault of Mom was not directed at B.E.S., Dad’s violent conduct was evidence of endangering B.E.S. ... Therefore, the evidence was legally and factually sufficient to support the trial court’s finding under subsection 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 I.B., Jr., a Child · filed 2022-04-28(b)(1)(E)

We hold that the evidence, viewed with the appropriate deference, was factually sufficient for the factfinder to reasonably form a firm conviction or belief that Mother had engaged in conduct or had knowingly placed I.B. with persons who had engaged in conduct that endangered his physical or emotional well-being.

Evidence of a parent's methamphetamine offense and domestic violence can be sufficient to establish a violation of subsection (b)(1)(E).

in the Interest of T.M., a Child · filed 2022-05-04(b)(1)(E)

We conclude that the evidence is sufficient to establish that Appellant violated subsection 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; violence against the other parent can qualify.

in the Interest of H.D.D.B, a Child · filed 2022-06-23(b)(1)(E)

Here, Father endangered the child by physically abusing Mother. ... We therefore hold that the evidence is both legally and factually sufficient to support the trial court’s termination of Father’s parental rights under Subsection (E).

Subsection (b)(1)(E) permits termination when a parent’s conduct, or conduct the parent allows by others, endangers a child’s physical or emotional well-being.

S. S. v. Texas Department of Family and Protective Services · filed 2022-07-07(b)(1)(E)

Given Father’s “long history of drug use and irresponsible choices,” see J.F.-G., 627 S.W.3d at 316-17—his criminal history; his knowledge of Mother’s drug involvement and failure to seek a safer home for the child; his own untreated drug use, which led to an episode of methamphetamine-induced psychosis; and his ensuing incarceration, which meant that he had had no contact with S. since she was about four months old and that he was unable to work any Department services—we hold that sufficient evidence supports the trial court’s finding that Father engaged in conduct or allowed S. to remain with others who engaged in conduct that endangered her physical or emotional well-being.

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows that a parent's conduct, or knowing placement of a child with another person, endangers the child's physical or emotional well-being.

in the Interest of A.M.R., a Child · filed 2022-07-20(b)(1)(E)

Viewing the evidence with the appropriate standards, we find that the evidence was legally and factually sufficient for the jury to have found that Stephanie "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).

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 A.N. and A.N., Children · filed 2022-06-09(b)(1)(E)

Accordingly, we hold the evidence is legally and factually sufficient to support the trial court’s Subsection (E) finding, and we affirm the trial court’s order terminating Mother’s parental rights to the Twins.

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

in the Interest of S.R. & N.R., Children · filed 2022-06-17(b)(1)(E)

Under this record, we conclude the evidence is both legally and factually sufficient to support the first prong of the termination inquiry. We overrule Mother’s sufficiency challenges to the trial court’s determination that she endangered the children.

Section 161.001(b)(1)(E) permits termination when a parent engages in a voluntary, deliberate course of conduct that endangers a child.

in the Interest of E.A.D., a Child · filed 2022-07-11(b)(1)(E)

These same facts established Mother engaged in a course of conduct endangering to her child for a finding under Subsection E.

Section 161.001(b)(1)(E) allows termination when clear and convincing evidence shows that a parent’s course of conduct endangered the child.

in the Interest of T.L.C., a Child · filed 2022-07-21(b)(1)(E)

Here, based upon evidence that Appellant placed T.L.C. in an unsafe situation in order to hide her from the Department, used cocaine, engaged in domestic violence, and continued to be in a relationship with the man with whom she engaged in domestic violence, the trial court could have reasonably found by clear and convincing evidence that Appellant had engaged in a course of conduct that endangered T.L.C.

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

in the Interest of E.P., a Child · filed 2022-07-27(b)(1)(E)

Because we have found that the evidence was sufficient as to Section 161.001(b)(1)(E), it is not necessary to address Kirsten's first issue or Nikobe's first or third issues relating to the other predicate acts.

Subsection (b)(1)(E) permits termination when a parent’s conduct, or the conduct of someone with whom the parent knowingly leaves the child, endangers the child.

in the Interest of K.S., a Child · filed 2022-08-03(b)(1)(E)

We find that the evidence is sufficient to support the trial court’s findings that Mother knowingly engaged in conduct or knowingly placed K.S. with persons who engaged in conduct that endangers 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 M.T. a Child v. Texas Department of Family and Protective Services · filed 2022-08-09(b)(1)(E)

Accordingly, the evidence is legally and factually sufficient to support termination of Mother’s parental rights 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 A.B. and D.B., Children · filed 2022-08-19(b)(1)(E)

From the above-recited evidence, we conclude that the record firmly established that Mother’s continued drug use and returned exposure to Father despite his drug use and domestic violence, which the children had witnessed in the past, constituted a course of conduct that endangered the children’s physical and emotional well-being.

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 P.R., a Child · filed 2022-08-24(b)(1)(E)

Viewing the evidence with the appropriate standards, we find that the evidence was legally and factually sufficient for the trial court to have found by clear and convincing evidence that Phillip engaged in conduct which endangered P.R.'s physical and emotional well-being pursuant to 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.

in the Interest of L.S., a Child · filed 2022-08-24(b)(1)(E)

Upon our review of the record under the appropriate standards for determining the legal and factual sufficiency of the evidence, we find that the evidence was legally and factually sufficient for the trial court to have found that Twytanisha engaged in conduct that endangered the physical and emotional well-being of the child pursuant to 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; domestic violence and failure to address it can support that finding.

in the Interest of S.W., a Child · filed 2022-08-25(b)(1)(E)

We hold that the evidence, viewed with the appropriate deference, was factually sufficient for the trial court to reasonably form a firm conviction or belief that Father had engaged in conduct that endangered S.W.’s physical or emotional well-being.

Section 161.001(b)(1)(E) allows 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 Q.R.W.a/k/a Q.W. S.R.W., Children v. Texas Department of Family and Protective Services · filed 2022-09-08(b)(1)(E)

Further, in view of the entire record, we conclude that 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 predicate ground (E). We accordingly conclude that the evidence is legally and factually sufficient to support the trial court’s finding.

Subsection (b)(1)(E) permits termination when a parent’s course of conduct endangers a child’s well-being.

in the Interest of F.C., D.C., and H.C., Children · filed 2022-09-22(b)(1)(E)

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

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 N.H., M.H., K.R., B.K., H.K., H.K., and H.T., Children · filed 2022-09-22(b)(1)(E)

And we hold that there is some evidence of endangering conduct on which a reasonable factfinder could have formed a firm belief or conviction that Mother had engaged in conduct that endangered their physical or emotional well-being.

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

in the Interest of K.P. and Z.S. · filed 2022-08-11(b)(1)(E)

Reviewing all the evidence in the light most favorable to the termination findings under subsection E, we hold the trial court could reasonably have formed a firm belief or conviction that Mother and Father, through their acts or omissions, endangered their children’s physical or emotional well-being.

Section 161.001(b)(1)(E) permits termination based on a parent’s course of conduct that endangers another child, even if the child at issue was never in the parent’s care.

in the Interest of L.M., a Child · filed 2022-09-22(b)(1)(E)

Based upon the evidence presented at trial regarding the parents’ conduct that was directed at R.M., the trial court could have reasonably found by clear and convincing evidence that the mother and the father had engaged in a course of conduct that endangered L.M.—even though L.M. had not ever been in the care of the parents after his birth. See J.O.A., 283 S.W.3d at 345. Therefore, we hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to both parents under subsection (E).

Subsection (b)(1)(E) supplies a ground for 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 B.N. · filed 2022-09-29(b)(1)(E)

From the record evidence as a whole, we conclude the trial court could have formed a firm belief or conviction that terminating Mother’s parental rights to Billy was proper under subsections E.

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

in the Interest of G.W., a Child · filed 2022-09-29(b)(1)(E)

Based on the evidence before the trial court, we hold that a reasonable factfinder could form a firm belief or conviction that Father had endangered Gabi.

Subsection (b)(1)(E) permits termination when a parent’s continuing conduct endangers a child’s physical or emotional well-being; persistent illegal drug use after removal can establish that conduct.

in the Interest of J. C. K. H. A/K/A J. H., a Child v. Department of a Family and Protective Services · filed 2022-09-29(b)(1)(E)

Having determined that there was legally and factually sufficient evidence to support the termination of Mother’s parental rights under section 161.001(b)(1)(E), we need not address issues two and three regarding termination under subsections (N) and (O).

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

in the Interest of B.B., a Child · filed 2022-10-19(b)(1)(E)

Because the record firmly established that Father engaged in conduct that endangered B.B.’s physical and emotional well-being, we find that legally and factually sufficient evidence supported the trial court’s finding under Ground E.

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

in the Interest of H. L. W. and S. K. W. v. Department of Family and Protective Services · filed 2022-11-08(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 clear and convincing evidence shows that a parent’s conduct, or knowing placement of a child with someone whose conduct endangers the child, threatens the child’s physical or emotional well-being.

G. R. v. Texas Department of Family and Protective Services · filed 2022-11-16(b)(1)(E)

Reviewing the record under the applicable standards, we conclude that legally and factually sufficient evidence supports the trial court’s finding that Father engaged in conduct or knowingly placed Infant with persons who engaged in conduct which endangered the physical or emotional well-being of Infant.

Section 161.001(b)(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 E. S. T. AKA E.T. a Child v. Department of Family and Protective Services · filed 2022-11-21(b)(1)(E)

Because we conclude the evidence is legally and factually sufficient to support the trial court’s finding under Section 161.001(b)(1)(E), we need not address Mother’s arguments that the evidence is legally and factually insufficient to support the trial court’s finding under Sections 161.001(b)(1)(D), (N), and (O).

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 I. F. Child v. Department of Family and Protective Services · filed 2022-11-03(b)(1)(E)

Mother’s failure to supervise Ivy, her drug use and criminal behavior, and her corresponding instability were legally and factually sufficient to allow a reasonable factfinder to conclude that her course of conduct jeopardized Ivy’s physical and 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 unsafe supervision and delayed medical care.

in the Interest of J.J.V.M.M., a Child · filed 2022-12-07(b)(1)(E)

We therefore hold legally and factually sufficient evidence supports the trial court’s finding that termination was warranted under section 161.001(b)(1)(E), and overrule T.S.’s arguments to the contrary.

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 T.J. · filed 2022-12-08(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 B.L. engaged in conduct or knowingly placed T.J. with persons who engaged in conduct that endangered T.J.’s physical or emotional well-being.

A parent’s failure to supervise children, complete a court-ordered service plan, and visit the children after removal can support an endangering-conduct finding.

in the Interest of D.A., D.A., C.A., S.A., and C.A., Children · filed 2022-12-22(b)(1)(E)

Even if we do not dwell on Father’s past criminality and his physical abuse of Mother, his failures to adequately supervise the children, to complete the service plan, and to visit the children after the removal sufficiently support the endangering-conduct finding.

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.W.W. and D.B.L., Children v. Texas Department of Family and Protective Services · filed 2022-12-29(b)(1)(E)

Based on all the foregoing evidence, we conclude that a fact finder could have formed a firm belief or conviction that its endangerment finding under subsection (E) was true.