Tex. Fam. Code Ann. § 161.001

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.

S. B. v. Texas Department of Family and Protective Services · filed 2023-01-26(b)(1)(E)

Because the evidence is legally and factually sufficient to support the district court’s endangerment finding under subsection (E), we need not consider whether the evidence also supports the court’s findings under subsection (D) or (O).

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

in the Interest of A.R., B.R., Jr., and B.R., Children · filed 2023-02-06(b)(1)(E)

Considering Mother’s drug use, history of domestic violence, and poor decision making, we conclude that the evidence was both legally and factually sufficient for a rational jury to find that Mother engaged in a course of conduct that exposed her children to loss or injury and that such conduct endangered the physical or emotional well-being of her children.

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 J.A.S. and J.A.S., Children · filed 2023-02-08(b)(1)(E)

When we view the evidence under the proper standards for legal sufficiency and factual sufficiency, we find that the evidence was legally and factually sufficient for the jury to have found by clear and convincing evidence that Mary and Dan "engaged in conduct … which endangered the physical or emotional well-being of the child[ren]." TEX. FAM. CODE ANN. § 161.001(b)(1)(E).

Subsection (E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being, including through exposure to substance abuse, unsafe home conditions, and domestic violence.

in the Interest of L.R.R. and A.P.R., Children · filed 2022-12-07(b)(1)(E)

Considering all the evidence, including Mom’s continuing relationship with Dad during the pendency of the case, Dad’s admitted ongoing drug and alcohol abuse, the cluttered and dirty home, the many empty beer cans littering the home, and Mom and Dad’s propensity to domestic violence, the trial court could have found that Mom’s course of conduct endangered the physical or emotional well-being of the children.

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

in the Interest of K.L. and C.L. v. Texas Department of Family and Protective Services · filed 2022-12-22(b)(1)(E)

Under the applicable standards of review, we conclude the evidence is factually sufficient to support the trial court’s finding that Mother endangered Kate and Caleb as described in subsection (E).

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

in the Interest of A.P.R. · filed 2023-02-09(b)(1)(E)

Because a pattern of drug abuse will support a finding of conduct endangering a child, and because Mother “knowingly placed the child with persons who engaged in conduct which endangers the physical or emotional well-being of the child[,]” the trial court was justified in finding by clear and convincing evidence that Mother had engaged in conduct endangerment when she agreed to let Alan live with Father.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being; repeated incarceration and evidence of violent conduct may support that finding.

in the Interest of J.B., a Child · filed 2023-02-09(b)(1)(E)

Likewise, having performed an exacting review of the entire record, we conclude that the evidence is factually sufficient to support the trial court’s endangerment-by-conduct finding.

Subsection (b)(1)(E) permits termination when a parent’s conduct endangers a child, including through domestic violence in the child’s home.

in the Interest of E.C. and N.C., Children · filed 2022-12-28(b)(1)(E)

We find that the evidence is sufficient to support the trial court’s findings that Father knowingly engaged in conduct or knowingly placed E.C. and N.C. with persons who engaged in conduct that endangers the child.

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

J. C. and A. C. v. Texas Department of Family and Protective Services · filed 2023-02-23(b)(1)(E)

Considering the entire record, we conclude that a reasonable factfinder could form a firm belief or conviction that appellants knowingly engaged in a course of conduct that endangered the children. See Tex. Fam. Code. § 161.001(b)(1)(E). The evidence is therefore factually sufficient to support those findings.

Subsection (b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being, including knowingly exposing the child to an alleged abuser.

In the Interest of A.P. and M.P., Children v. the State of Texas · filed 2023-03-01(b)(1)(E)

Based on our review of the record under the appropriate standards for determining the legal and factual sufficiency of the evidence, we conclude that the evidence was legally and factually sufficient to support the trial court’s finding R.P. engaged in conduct that endangered the physical and emotional well-being of A.P. and M.P. pursuant to section 161.001(b)(1)(E) of the Texas Family Code and that termination of R.P.’s parental rights to A.P. and M.P. is in the best interest of the children.

Continued drug use and contact with a violent partner can support a finding of endangering conduct under Section 161.001(b)(1)(E).

In the Interest of N. E. a Child v. Department of Family and Protective Services · filed 2023-03-16(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 overrule Mother’s second issue.

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 the child.

In the Interest of R.M., a Child v. the State of Texas · filed 2023-03-30(b)(1)(E)

Based upon the evidence presented at trial regarding the mother’s conduct and care of R.M., the jury could have reasonably found by clear and convincing evidence that the mother engaged in a course of conduct that endangered R.M. Therefore, we hold that the evidence is legally and factually sufficient to uphold the finding under subsection (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 the child’s physical or emotional well-being.

In the Interest of M.H., a Child v. the State of Texas · filed 2023-03-30(b)(1)(E)

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

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.S., a Child v. the State of Texas · filed 2023-04-13(b)(1)(E)

Based upon evidence that showed the domestic violence that occurred in J.S.’s presence and Appellant’s failure to be protective of J.S. in light of the violent nature of J.S.’s father, we conclude that the trial court could have found by clear and convincing evidence that Appellant had engaged in conduct or knowingly placed J.S. with persons who engaged in conduct that endangered the child’s physical or emotional well-being. We hold that the evidence is legally and factually sufficient to uphold the trial court’s finding as to Appellant under subsection (E).

Under subsection (E), a continuing course of illegal drug activity can constitute conduct that endangers a child’s physical or emotional well-being.

In the Interest of B. S., Child v. Texas Department of Family and Protective Services · filed 2023-04-27(b)(1)(E)

From this evidence, the trial court could have reasonably concluded that Mother’s history of illegal drug activity, which continued during the pendency of this case, including during the monitored return, constituted a course of conduct that endangered Beth’s physical and emotional well-being.

Section 161.001(b)(1)(E) permits termination when a parent’s course of criminal conduct and drug use endangers a child.

In the Interest of L.D.T.P., a Child v. the State of Texas · filed 2023-04-27(b)(1)(E)

The evidence would support a finding that Father had a history of criminal conduct, incarceration, and drug use that endangered the Lazaro and would continue to engage in such behavior. We conclude that under these circumstances, the factfinder could have formed a firm belief or conviction that its endangerment finding under subsection (E) was true.

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

A. B. v. Texas Department of Family and Protective Services · filed 2023-05-04(b)(1)(E)

Contrary to Father’s contentions, there is sufficient evidence in the record that Father himself engaged in a course of conduct that endangered Daughter.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child’s physical or emotional well-being; marijuana use during pregnancy that results in a positive THC test at birth can support that finding.

In the Interest of M.I.J., a Child v. the State of Texas · filed 2023-05-31(b)(1)(E)

Therefore, viewing the evidence with deference to the fact finder’s conclusions and indulging every reasonable inference, we hold there is legally sufficient evidence to support the trial court’s finding that S.S. engaged in a course of conduct endangering the child’s physical and emotional well-being 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 E.J.M., a Child v. the State of Texas · filed 2023-05-31(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 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.

In the Interest of D.M., a Child v. the State of Texas · filed 2023-06-07(b)(1)(E)

Based on a review of the direct and circumstantial evidence contained in the record, we conclude that legally and factually sufficient evidence supports the trial court’s findings that Father engaged in conduct which endangered the children’s physical or emotional well-being, satisfying subsection (E).

Section 161.001(b)(1)(E) treats purchasing illegal drugs for a child and using those drugs with the child as endangering conduct.

In the Interest of L.N., a Child v. the State of Texas · filed 2023-06-07(b)(1)(E)

Purchasing illegal drugs for a child that results in that child’s arrest is certainly endangering conduct, and using illegal drugs with a child is endangering as well.

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

In the Interest of R.L.K., a Child v. the State of Texas · filed 2023-06-08(b)(1)(E)

Mother’s use of those drugs while pregnant endangered R.L.K., and her continued use of the drugs after R.L.K.’s removal, along with her failure to address that conduct through the available treatment services, shows that she engaged in a voluntary, deliberate, and conscious course of conduct and omissions that endangered R.L.K.’s physical and emotional well-being.

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 children.

In the Interest of M.M. and P.M., Children v. the State of Texas · filed 2023-06-15(b)(1)(E)

Therefore, 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; repeated drug use and the child’s positive drug tests can support that ground.

In the Interest of J.S., a Child v. the State of Texas · filed 2023-06-15(b)(1)(E)

Based upon evidence of Appellant’s use of illegal drugs, including multiple positive tests for herself and her two-year-child, the trial court could have found by clear and convincing evidence that Appellant had engaged in conduct or knowingly placed J.S. with persons who engaged in conduct that endangered the child’s physical or emotional well-being. In addition to affecting her ability to care for J.S., the fact that J.S. also tested positive for methamphetamine is significant because it indicated that it had a direct impact on his life. 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 continued drug use while custody is in jeopardy supports a finding of conduct endangerment.

In the Interest of B.M. and L.M. v. the State of Texas · filed 2023-05-04(b)(1)(E)

Because a parent’s continued drug use when the custody of their children is in jeopardy supports a finding of endangerment, we cannot conclude that the jury lacked sufficient evidence to find that Mother’s and Father’s drug use constituted conduct endangerment.

Section 161.001(b)(1)(E) allows a finding of endangerment based on a parent's course of conduct, including drug use and failure to provide a stable home.

In the Interest of E.G.P. v. the State of Texas · filed 2023-06-15(b)(1)(E)

We conclude Mother committed the predicate acts enumerated in section 161.001(b)(1)(E).

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

In the Interest of G.K., a Child v. the State of Texas · filed 2023-05-25(b)(1)(E)

Based upon evidence that showed the domestic violence that occurred in G.K.’s presence and the very violent nature of the relationship between Appellant and G.K.’s father, we conclude that the trial court could have found by clear and convincing evidence that Appellant had engaged in conduct or knowingly placed G.K. with persons who engaged in conduct that endangered the child’s physical or emotional well-being.

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

E. J. v. Texas Department of Family and Protective Services · filed 2023-06-23(b)(1)(E)

Contrary to Father’s contentions, there is legally sufficient evidence in the record that Father engaged in a course of conduct that endangered the physical and 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.

In the Interest of A.A v. a Child v. the State of Texas · filed 2023-06-28(b)(1)(E)

Based on our review of the record under the appropriate standards for determining legal and factual sufficiency of the evidence, we conclude that the evidence is legally and factually sufficient to support the trial court’s findings that Mother and Father engaged in conduct that endangered the physical and emotional well-being of A.A.V. pursuant to subsection 161.001(b)(1)(E) of the Texas Family Code.

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 J.A.A.A., M.L.T. A/K/A M.T., J.H.M. Jr., A/K/A J.N., Children v. the State of Texas · filed 2023-07-13(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 Mother’s parental rights was justified under section 161.001(b)(1)(E).

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

In the Interest of S.M. and J.M., Children v. the State of Texas · filed 2023-07-13(b)(1)(E)

On this record, a reasonable factfinder—whether viewing the evidence in the light most favorable to the judgment or weighing all of the disputed evidence, see In re A.C., 560 S.W.3d 624, 630–31 (Tex. 2018)—could have formed a firm belief or conviction that Mother’s course of conduct endangered the children’s well-being.

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

In the Interest of T.K. and G.K., Children v. the State of Texas · filed 2023-07-14(b)(1)(E)

Because the trial court’s ground E finding was supported by sufficient evidence, we overrule Father’s point of error.

Repeated domestic violence by a parent can support an endangerment finding under section 161.001(b)(1)(E).

In the Interest of J.S.H.,D.P.C.H., B.I.H., C.C.H., and C.L.H.,II, Children v. the State of Texas · filed 2023-07-19(b)(1)(E)

The testimony regarding repeated incidences of domestic violence perpetrated by Father C.H. support’s the trial court’s endangerment finding 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, even if the child suffers no actual injury.

In the Interest of J.E. and A.E., Children v. the State of Texas · filed 2023-08-10(b)(1)(E)

Accordingly, 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 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 M.M., a Child v. the State of Texas · filed 2023-08-14(b)(1)(E)

Because we find that legally and factually sufficient evidence supported the jury’s findings under ground E and that termination of Mother’s parental rights was in the best interest of M.M., we affirm the trial court’s judgment.

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

In the Interest of A.H., a Child v. the State of Texas · filed 2023-08-14(b)(1)(E)

The statute requires a voluntary, deliberate, or conscious course of endangering conduct by the parent.

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

In the Interest of N.W., a Child v. the State of Texas · filed 2023-08-17(b)(1)(E)

In sum, this evidence of Mother’s substance abuse, criminal and domestic violence history, her relationship with Nick, her relationships with her other children, and her dealings with the Department constitute legally and factually sufficient evidence to support the trial court’s subsection (E) finding.

A parent’s drug use, criminal conduct, and inability to provide a stable home can support a finding of endangering conduct under subsection (b)(1)(E).

In the Interest of B.F., a Child v. the State of Texas · filed 2023-08-31(b)(1)(E)

Viewing all the evidence in the light most favorable to the trial court’s judgment and recognizing that the factfinder is the sole arbiter of the witnesses’ credibility and demeanor, we hold that there is some evidence of endangering conduct on which a reasonable factfinder could have formed a firm belief or conviction that Appellant had engaged in conduct that endangered B.F.’s physical or emotional well-being.

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

In the Interest of A.C., a Child v. the State of Texas · filed 2023-09-21(b)(1)(E)

Therefore, 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 a parent's course of conduct, or knowing placement with another person, endangered a child's physical or emotional well-being.

In the Interest of R.D., J.D., and H.D., Children v. the State of Texas · filed 2023-07-05(b)(1)(E)

There was clear and convincing evidence of domestic violence, drug use, threats with a gun, and physical and emotional abuse of the children to support termination under subsection (E).

Section 161.001(b)(1)(E) requires a voluntary, deliberate, and conscious course of conduct by the parent to establish endangerment.

M.A.R. v. Department of Family and Protective Services · filed 2023-08-08(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.

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

In the Interest of S v. J v. and K v. Children v. the State of Texas · filed 2023-09-14(b)(1)(E)

Accordingly, we hold that the evidence was both legally and factually sufficient to show that Father engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered the children’s physical or emotional well-being.

Abuse of one child can support an endangerment finding as to another child.

In the Interest of D.R., R.R., A.R., and J.R., Children v. the State of Texas · filed 2023-09-14(b)(1)(D), (E)

Thus, if a parent abuses a child, that conduct can support an endangerment finding as to another child.

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows conduct endangering a child’s physical or emotional well-being; the court may consider the parent’s conduct together.

In the Interest of E.E., a Child v. the State of Texas · filed 2023-09-27(b)(1)(E)

In short, the trial court was free to add together all the foregoing when considering whether the Department proved the elements of § 161.001(b)(1)(E). And, our adding it together leads us to conclude that the trial court had before it clear and convincing evidence establishing those elements. So, its finding of the same has both legally and factually sufficient evidentiary support.

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 K.J. and C.W., Children v. the State of Texas · filed 2023-10-05(b)(1)(E)

A reasonable factfinder—whether viewing the evidence in the light most favorable to the judgment or weighing all of the disputed evidence—could have formed a firm belief or conviction that Father’s course of conduct endangered the children’s well-being.

Section 161.001(b)(1)(E) requires clear and convincing evidence that a parent endangered the child through a course of conduct or knowingly placed the child with someone who did.

In the Interest of N.L.S., E.J.C., AKA E.J.C., Children v. Department of Family and Protective Services · filed 2023-10-12(b)(1)(E)

Viewing the evidence in the light most favorable to the trial court’s finding, we conclude that the trial court could not have formed a firm belief or conviction that father engaged, or knowingly placed N.L.S. with persons who engaged, in conduct that endangered N.L.S.’s physical or emotional well-being.

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

In the Interest of S.L.G and A.J.G, Children v. the State of Texas · filed 2023-10-19(b)(1)(E)

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 a parent’s continued drug use and pattern of domestic violence endanger a child’s physical or emotional well-being.

In the Interest of A.B. and D.B., Children v. the State of Texas · filed 2023-11-13(b)(1)(E)

From the above-recited evidence, we conclude that the record firmly established that Mother’s and Father’s continued drug use and pattern of 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 engaged in a course of conduct endangering a child’s physical or emotional well-being.

In the Interest of A.E., P.E., and Q.S. AKA Q.S., Jr., Children v. the State of Texas · filed 2023-11-27(b)(1)(E)

From the above-recited evidence, we conclude that the record firmly established that Mother engaged in a course of conduct that endangered the children’s physical and emotional well-being. As a result, we find that legally and factually sufficient evidence supported the trial court’s finding under ground E.

Section 161.001(b)(1)(E) permits termination when a parent’s voluntary, deliberate course of conduct endangers a child, including through sexual abuse of another child.

W. B. v. Texas Department of Family and Protective Services · filed 2023-11-30(b)(1)(E)

We conclude that the above evidence is legally and factually sufficient to support the trial court’s findings that Father engaged in a voluntary, deliberate, and conscious course of conduct that endangered Charlie’s physical or emotional well-being.

Evidence of a parent’s threats to a child’s caregiver and drug-related conduct can support a finding under subsection (b)(1)(E).

In the Interest of A.P., a Child v. the State of Texas · filed 2023-12-07(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 a parent’s voluntary course of conduct endangers a child’s physical or emotional well-being.

In the Interest of A.B., a Child v. the State of Texas · filed 2023-12-22(b)(1)(E)

Mother’s voluntary, deliberate, and conscious acts constitute more than a single act of conduct. On this record, the trial court could have formed a firm belief or conviction that Mother engaged in a course of conduct that endangered A.B.’s physical or emotional well-being. See TEX. FAM. CODE ANN. § 161.001(b)(1)(E). Accordingly, the evidence is legally and factually sufficient to support parental termination under subsection (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 dangerous surroundings or engaged in, or knowingly placed the child with others engaged in, endangering conduct.

in the Interest of R. M., C. W. & L. W., Children · filed 2021-10-20(b)(1)(D), (b)(1)(E)

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

Section 161.001(b)(1)(D) and (E) require evidence that a parent knowingly exposed a child to an endangering environment or engaged in a course of endangering conduct.

in the Interest of S.K.G., Child · filed 2021-10-21(b)(1)(D), (E)

Because the evidence presented at the termination hearing mainly dealt with subsections N and O, we find the evidence was insufficient to support the trial court’s findings under subsection D and 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 T.M.R., a Child · filed 2021-10-28(b)(1)(E)

Considering all of this evidence in the light most favorable to the judgment, we conclude that a reasonable trier of fact could have formed a firm belief or conviction, based on clear and convincing evidence, that J.R.R. engaged in a course of conduct which endangered T.M.R.’s physical or emotional well-being.

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

C. F. v. Texas Department of Family and Protective Services · filed 2021-10-29(b)(1)(D), (E)

Viewing this and the remaining evidence in the light most favorable to the trial court’s subsection (D) and (E) findings, and considering the undisputed contrary evidence, we conclude that the trial court could have formed a firm belief or conviction that the findings were true.

Subsections (b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent endangered a child through unsafe surroundings or a course of conduct, respectively.

in the Interest of A.S. · filed 2021-11-04(b)(1)(D), (E)

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

Under subsections (b)(1)(D) and (E), persistent mental-health issues, illegal drug use, and criminal activity can support findings of an endangering environment and endangering conduct.

in the Interest of U.L., Jr., a Child · filed 2021-11-10(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 Uriah to remain in conditions or surroundings that had endangered Uriah’s emotional or physical well-being and that Father had engaged in conduct that had endangered Uriah’s physical or emotional well-being.

Under subsections (b)(1)(D) and (E), prenatal substance use, a suicide attempt, and untreated mental instability can support endangerment findings even without evidence of missed drug tests.

J. M. v. Texas Department of Family and Protective Services · filed 2021-11-10(b)(1)(D), (E)

Viewing the evidence under the applicable standard of review, even without considering the evidence of missed drug testing during the pendency of the case, we conclude that the evidence was legally sufficient to support the trial court’s findings under subsections (D) and (E).

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

in the Interest of B.K. and A.K., Children · filed 2021-12-09(b)(1)(D)–(E)

Considering all the evidence detailed above, we hold it legally sufficient to support the trial court’s endangerment findings against Father.

Section 161.001(b)(1)(D) addresses endangering surroundings, while (E) addresses a parent’s endangering conduct, including knowingly placing a child with people whose conduct endangers the child.

in the Interest of J.L.B., a Child · filed 2021-12-15(b)(1)(D), (E)

Having examined the entire record, we find that the trial court could reasonably form a firm belief or conviction that Mother knowingly placed or knowingly allowed J.L.B. to remain in conditions or surroundings which endangered her physical or emotional well- being and engaged in conduct which endangered J.L.B.’s emotional and physical well- being.

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

in the Interest of J.B., a Child · filed 2021-12-30(b)(1)(D), (E)

At bottom, this evidence is legally and factually sufficient to support both endangerment grounds.

Section 161.001(b)(1)(E) requires a connection between the timing of a parent's criminal conduct and the parent's knowledge of paternity to support an endangerment finding based on that conduct.

in the Interest R.K.P-R., a Child · filed 2022-01-19(b)(1)(E)

There must be some connection between the timing of some part of Father's criminal offenses and Father's knowledge of paternity to support a finding that a child, whether it be the child whose relationship is terminated or some other child in Father's life, has been endangered by Father's criminal behavior.

Section 161.001(b)(1)(D) permits termination for endangering surroundings, while subsection (E) permits termination for an endangering course of conduct, when proved by clear and convincing evidence.

in the Interest of L.B., L.B., K.B., and K.B. · filed 2022-01-20(b)(1)(D), (E)

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

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

in the Interest of J.C.W., K.R.W. and B.L.W. · filed 2022-01-20(b)(1)(D), (E)

We conclude that the Department established, by clear and convincing evidence, that Mother committed the predicate acts enumerated in subsections D and 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 environment or the parent's conduct.

in the Interest of S.P., a Child · filed 2022-01-26(b)(1)(D), (E)

Considering the entire record, we conclude that the evidence was both legally and factually sufficient to support termination under grounds D and E.

Section 161.001(b)(1)(D) permits termination based on a single act or omission that endangers a child.

in the Interest of M.L.H., A.E.H. and N.E.H., Children · filed 2022-03-01(b)(1)(D)

Subsection D permits termination based upon a single act or omission.

Subsections (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.

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

On this record, we conclude that the evidence—including Mother’s history of drug use, Mother’s continued drug use after removal, the children’s exposure to family violence, and Mother’s involvement of the children in criminal activity—was legally and factually sufficient to support termination under subsections (D) and (E).

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

A. R. v. Texas Department of Family and Protective Services · filed 2022-03-04(b)(1)(D), (E)

We conclude that the evidence is legally and factually sufficient to support the district court’s findings that Mother endangered Daughter 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 exposed a child to an endangering environment or engaged in endangering conduct.

in the Interest of E.G., a Child · filed 2022-03-04(b)(1)(D), (E)

The trial court could have concluded that Mother’s ongoing relationship with Father jeopardized her substance abuse recovery, and posed a risk to E.G.’s emotional and physical well-being.

Subsection (b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being and the evidence meets the clear-and-convincing standard.

in the Interest of C.U.D., S.L.D., A/K/A S.D., J.P.J.D., K.K.J.D., A.E.D., II, Children v. Texas Department of Family an · filed 2022-03-10(b)(1)(E)

We conclude that a reasonable fact finder could have formed a firm belief or conviction that Father engaged in conduct or knowingly placed the children with persons who engaged in conduct which endangers the physical or emotional well- being of the children. See Tex. Fam. Code Ann. § 161.001(b)(1)(E); In re A.C., 560 S.W.3d at 630–31. The evidence is both legally and factually sufficient.

Section 161.001(b)(1)(D) permits termination for knowingly exposing a child to endangering surroundings, while (E) permits termination for a course of conduct that endangers the child.

in the Interest of J.O. Jr., T.O., J.O. and W.O. · filed 2022-03-17(b)(1)(D), (E)

Deferring to the trial court’s credibility determinations and reviewing all the evidence in the light most favorable to the findings under subsections D and E, as we must, the trial court could reasonably have formed a firm belief or conviction that Mother, through her individual acts or omissions or a course of conduct, endangered the children’s physical or emotional well-being.

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

in the Interest of S.L., J.L., and L.L., Children · filed 2022-03-28(b)(1)(D), (E)

We conclude that the grounds upon which the trial court based its findings for termination are supported by clear and convincing evidence and are more than ample to show that termination was in the best interest of S.L. because Father knowingly allowed S.L. to remain in conditions that endangered her emotional well-being and engaged in conduct which endangered her emotional well-being.

Section 161.001 permits termination when a parent exposes a child to endangering conditions or conduct and termination is in the child’s best interest; actual injury is not required.

in the Interest of O v. Jr., J v. J v. and A v. · filed 2022-03-31(b)(1)(D), (b)(1)(E), (b)(2)

We conclude the evidence is legally and factually sufficient to support the trial court’s predicate findings terminating Father’s rights and the trial court’s best-interest finding.

Subsections (b)(1)(D) and (E) allow 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 E.M. and E.B. · filed 2022-04-07(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 Father (1) knowingly placed or knowingly allowed the children to remain in conditions or surroundings which endangered their physical or emotional well-being and (2) engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered the children’s physical or emotional well-being.

Subsections (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; domestic violence and prior endangerment of another child can support those findings.

in the Interest of E. K. H. · filed 2022-04-07(b)(1)(D), (b)(1)(E)

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

Subsections (b)(1)(D) and (E) address a parent’s knowing exposure of a child to endangering surroundings and conduct that endangers the child’s well-being.

Y. G. v. Texas Department of Family and Protective Services · filed 2022-04-19(b)(1)(D), (b)(1)(E)

Viewing the evidence under the applicable standards of review, we conclude that the evidence was legally and factually sufficient to support the jury’s findings that Father knowingly placed or knowingly allowed Child to remain in conditions or surroundings which endangered Child’s physical or emotional well-being and that he engaged in conduct or knowingly placed Child with persons who engaged in conduct which endangered Child’s physical or emotional 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.

in the Interest of W.M., a Child · filed 2022-04-27(b)(1)(D), (E)

We find that the evidence is legally and factually sufficient to support the trial court’s findings that Brandy 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 permits termination when clear and convincing evidence establishes endangerment through a child’s surroundings or a parent’s conduct and shows that termination is in the child’s best interest.

in the Interest of L.O., A.O. III, C.O., A.O., N.O., A.O. L.W. and T.J., Children · filed 2022-04-28(b)(1)(D), (b)(1)(E), (b)(2)

The record contains legally and factually sufficient evidence to allow a reasonable factfinder to form a firm belief or conviction that Mother had endangered the Children by their conditions or surroundings, that she had endangered the Children by her conduct, and that termination was in the best interest of the Children.

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.

in the Interest of B.A.S. and B.J.S., Children · filed 2022-05-03(b)(1)(D), (E)

We conclude the trial court could have reasonably formed a firm belief or conviction that, before her removal, Dad knowingly placed B.A.S. in surroundings which endangered her physical or emotional well-being. ... We further conclude the trial court could have reasonably formed a firm belief or conviction that Dad engaged in conduct that endangered B.A.S.’s physical or emotional well-being. ... Therefore, 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) and (E) allow termination for endangering conditions or conduct when clear and convincing evidence shows ongoing drug use, even without proof of actual injury to the child.

in the Interest of C.S. · filed 2022-05-12(b)(1)(D), (E)

Because the evidence of Mother’s ongoing marijuana use constitutes clear and convincing evidence of both condition endangerment and conduct endangerment, we will uphold the trial court’s findings as to sections (D) and (E) of § 161.001(b)(1).

Subsections (b)(1)(D) and (E) provide separate grounds for termination based on endangering conditions and endangering parental conduct, respectively.

J.M.F. v. Texas Department of Family and Protective Services · filed 2022-06-02(b)(1)(D), (E)

Taken together, the evidence was legally and factually sufficient to support termination under subsection D for knowingly placing or allowing the children to remain in conditions or surroundings that endangered their physical or emotional well-being. ... The evidence discussed above was legally and factually sufficient to support termination under subsection E based on the parents’ allegedly engaging in conduct which endangered the physical or emotional well-being of the children.

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

R. C. C. and N. T. v. Texas Department of Family and Protective Services · filed 2022-06-22(b)(1)(D), (E)

Viewing the evidence under the applicable standard of review, we conclude that the evidence was legally sufficient to support the jury’s findings that Father knowingly placed or knowingly allowed Child to remain in conditions or surroundings that endangered Child’s physical or emotional well-being and that he engaged in conduct or knowingly placed Child with persons who engaged in conduct that endangered Child’s physical or emotional well-being.

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 surroundings or engaged in or knowingly exposed the child to endangering conduct.

in the Interest of B.P. and T.P. · filed 2022-06-23(b)(1)(D), (E)

Viewing the evidence in the light most favorable to the trial court’s findings, we conclude that the factfinder could reasonably have formed a firm belief or conviction that Mother (1) knowingly placed or knowingly allowed the children to remain in conditions or surroundings which endangered their physical or emotional well-being and (2) engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered the children’s physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) address endangerment caused by a child’s environment and by a parent’s conduct.

in the Interest of M.T., a Child · filed 2022-06-30(b)(1)(D)–(E)

We conclude the evidence of the home’s condition at the time of removal––a condition that had not improved despite past Department intervention and community attempts to help Mother––as well as Mother’s attempt to shift responsibility for the children’s needs to them from herself supports the trial court’s endangerment findings.

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

in the Interest of J.B.C. AKA J.B.S. · filed 2022-07-05(b)(1)(D), (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 Jordan was proper 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 kept a child in endangering surroundings or engaged in endangering conduct.

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

Because we hold that the evidence is legally and factually sufficient to support the endangerment findings under Section 161.001(b)(1)(D) and (E), and because only one finding is necessary to sustain a parental-rights termination, we need not address Mother’s challenge to the trial court’s finding under Section 161.001(b)(1)(O).

Section 161.001(b)(1)(E) does not require proof that a parent knew of actual harm to the child.

N. K. v. Texas Department of Family and Protective Services · filed 2022-07-12(b)(1)(E)

And with respect to Father’s purported lack of knowledge of the conditions in Mother’s household, satisfaction of subsection (E) does not require actual knowledge of any harm that befalls the child.

Section 161.001(b)(1)(E) did not support termination where the father’s criminal conduct preceded his knowledge of the children and he neither engaged in later misconduct nor knowingly placed them with someone who endangered them.

in the Interest of A.T. and N.T., Children · filed 2022-07-27(b)(1)(E)

He had committed no criminal offenses or even had any behavioral misconduct during his incarceration before or after he found out about his potential paternity. ... However, there was no evidence that Joshua knowingly placed the twins with anyone who endangered them because he did not know of their existence at a time when he could have been involved in their placement. ... Because we find that the evidence was legally insufficient pursuant to Section 161.001(b)(1)(E), and that was the only predicate act upon which the termination was granted, we reverse the judgment of the trial court terminating Joshua's parental rights and remand this proceeding to the trial court.

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

in the Interest of D.P. and D.P. · filed 2022-07-28(b)(1)(D), (E)

The trial court could have reasonably inferred that Alice knowingly allowed both Donna and Darren to remain in an environment that endangered their physical well-being and that she engaged in conduct that endangered their physical well-being. It was within the trial court’s province to judge Alice’s demeanor, to disbelieve her testimony that she did not know how Donna and Darren were injured, and to infer that she knew of their injuries and how they occurred, supporting its findings under both subsection D and E.

Section 161.001 permits termination when clear and convincing evidence establishes endangering conditions or conduct and shows that termination is in the children’s best interest.

in the Interest of C.W.S. and J.S. · filed 2022-07-28(b)(1)(D), (E), (b)(2)

We conclude that the Department established, by clear and convincing evidence, that Father committed the predicate acts enumerated in sections 161.001(b)(1)(D) and (E) and that termination of Father’s parental rights is in the best interest of C.W.S and J.S.

Subsections (D) and (E) allow termination when clear and convincing evidence shows that a parent exposed a child to endangering surroundings and engaged in endangering conduct.

in the Interest of K.D., a Child · filed 2022-07-29(b)(1)(D), (b)(1)(E)

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

Subsections (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.

in the Interest of J.J.M., Children · filed 2022-08-11(b)(1)(D), (E)

We find 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 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)(D) and (E) allow termination when clear and convincing evidence shows that a parent endangered a child through the child’s living conditions or the parent’s conduct.

in the Interest of G.A.B. · filed 2022-08-18(b)(1)(D), (E)

We have carefully reviewed the entire record, and after examining the evidence we hold that a reasonable trier of fact could have formed a firm belief or conviction that Father engaged in conduct whereby Gabrielle’s physical or emotional well-being was endangered by the parents’ conduct and by her living conditions while in their care.

Section 161.001(b)(1)(E) permits termination when a parent’s actions or failures to act endanger a child’s physical or emotional well-being.

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

From this evidence, a factfinder could have reasonably formed a firm conviction or belief that the Department had proven that Father’s actions and his failures to act endangered Matthew’s physical or mental well-being. The evidence was therefore factually sufficient. Because the evidence was factually sufficient, it was also legally sufficient.

Subsections (b)(1)(D) and (E) permit termination when a parent knowingly allows a child to remain in dangerous conditions or knowingly places the child with someone whose conduct endangers the child.

F. H. and L. L. v. Texas Department of Family and Protective Services · filed 2022-09-29(b)(1)(D), (E)

Reviewing the record under the applicable standard, we conclude that a reasonable factfinder could form a firm belief or conviction that Father knowingly allowed Child to remain in dangerous conditions and knowingly placed her with a person—Mother—who engaged in a dangerous course of conduct.

Section 161.001(b)(1)(D) permits termination when a parent knowingly places or leaves a child in endangering surroundings; subsection (E) permits termination for endangering conduct.

in the Interest of D. A. and G. A., Children · filed 2022-09-30(b)(1)(D), (E)

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

Subsections (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 A.C., a Child · filed 2022-10-04(b)(1)(D), (E)

Considering the undisputed evidence in the record, we conclude the evidence is legally and factually sufficient to support the trial court’s determination that Mother knowingly placed or knowingly allowed A.C. to remain in conditions or surroundings that endangered his physical or emotional well-being and engaged in conduct or knowingly placed A.C. with persons who engaged in conduct which endangered A.C.’s physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent kept children in endangering conditions and engaged in an endangering course of conduct.

in the Interest of J.H. and K.H., Children · filed 2022-11-03(b)(1)(D), (b)(1)(E)

The evidence is legally and factually sufficient to uphold the trial court’s findings under subsections (D) and (E).

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

S. W. and M. S. v. Texas Department of Family and Protective Services · filed 2022-10-05(b)(1)(D), (E)

Based on this record and the trial court’s determination of credibility, we hold that sufficient evidence supported the trial court’s finding of grounds under Subsections (D) and (E).

Section 161.001(b)(1)(D) and (E) allow termination when clear and convincing evidence shows that a parent knowingly left a child in endangering surroundings or engaged in a deliberate course of conduct that endangered the child, and termination serves the child’s best interest.

in the Interest of R.W. and G.W., Children · filed 2022-10-18(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 Mother had knowingly placed or had knowingly allowed R.W. and G.W. to remain in conditions or surroundings that endangered their emotional or physical well-being and that Mother had engaged in conduct that endangered their physical or emotional well-being. See id. § 161.001(b)(1)(D), (E).

Section 161.001(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 A.L.S., A.L.S., S.A.S., Children · filed 2022-10-19(b)(1)(D), (E)

After reviewing the entire record, we conclude the evidence that is contrary to the trial court’s findings is not so compelling that it would prevent a reasonable factfinder from forming a firm belief or conviction that Father knowingly allowed the children to remain in endangering conditions and engaged in conduct that endangered the children.

Subsections (b)(1)(D) and (E) permit termination when clear and convincing evidence shows an endangering environment or a parent’s endangering conduct.

in the Interest of T.D., a Child · filed 2022-10-20(b)(1)(D), (E)

Because we hold that the evidence is legally and factually sufficient to support the endangerment findings under Section 161.001(b)(1)(D) and (E), and because only one finding is necessary to sustain a parental-rights termination, we need not address Mother’s challenge to the trial court’s finding under Section 161.001(b)(1)(O).

Subsections (b)(1)(D) and (E) provide grounds for termination when a parent knowingly leaves children in endangering surroundings or knowingly exposes them to endangering conduct.

A. M. v. Texas Department of Family and Protective Services · filed 2022-10-20(b)(1)(D), (E)

Viewing the evidence under the applicable standards of review, we conclude that the evidence was legally and factually sufficient to support the jury’s findings that Mother knowingly placed or knowingly allowed A.W. and S.N. to remain in conditions or surroundings which endangered their physical or emotional well-being and that she engaged in conduct or knowingly placed A.W. and S.N. with persons who engaged in conduct which endangered their physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) permit termination based on conditions that endanger a child or a parent’s course of endangering conduct.

A. K. and T. A. v. Texas Department of Family and Protective Services · filed 2022-10-27(b)(1)(D), (E)

Viewing the evidence under the applicable standards of review, we conclude that it was legally sufficient to support the endangerment findings against Mother and legally and factually sufficient to support the endangerment findings against Father.

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

in the Interest of S. A. and R.T., Children · filed 2022-10-31(b)(1)(D), (b)(1)(E)

Therefore, we hold that the evidence is legally and factually sufficient to support termination of S.T.’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 kept a child in endangering surroundings or engaged in endangering conduct.

in the Interest of A.P., B.P., D.P., and A.P., Children · filed 2022-11-03(b)(1)(D), (E)

Thus, the evidence is legally and factually sufficient to support the trial court’s two endangerment predicate findings under Subsections (D) and (E).

Section 161.001(b)(1)(D) and (E) provide endangerment grounds for termination when a parent knowingly exposes a child to dangerous conditions or engages in or knowingly exposes the child to endangering conduct.

H. G. v. Texas Department of Family and Protective Services · filed 2022-11-23(b)(1)(D), (E)

We thus conclude that the evidence was factually sufficient under Subsections (D) and (E) and overrule these two issues.

Subsections (b)(1)(D) and (E) require clear and convincing evidence that a parent knowingly exposed a child to endangering surroundings or engaged in endangering conduct.

in the Interest of C.A.L., a Child · filed 2022-12-05(b)(1)(D), (E)

We conclude the evidence is legally and factually insufficient to show by clear and convincing evidence that Father knowingly placed or knowingly allowed C.A.L. to remain in conditions or surroundings which endanger his physical or emotional well-being, see TEX. FAM. CODE ANN. § 161.001(b)(1)(D), or “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,” see id. § 161.001(b)(1)(E).

Prenatal drug exposure that endangers a child can support termination under subsections (D) and (E).

in the Interest of I.R.Z, a Child v. Texas Department of Family and Protective Services · filed 2022-12-08(b)(1)(D), (E)

Multiple witnesses testified, without objection, to Isaac’s stay in the NICU immediately after his birth because of his positive drug test and his drug exposure. Viewing this evidence in the light most favorable to the judgment, this evidence supports the trial court’s finding of endangerment.

Section 161.001(b)(1)(D) and (E) allow endangerment findings based on dangerous surroundings or a parent’s endangering conduct; a parent’s efforts to evade child-protection authorities, discouragement of needed medication, failure to visit, and failure to follow a service plan can support those findings.

in the Interest of Y.W., a Child · filed 2022-12-22(b)(1)(D)–(E)

Having determined that the evidence was both legally and factually sufficient to support the trial court’s endangerment predicate findings, we affirm the remainder of the judgment as modified.

Section 161.001 permits termination when clear and convincing evidence shows that a parent knowingly allowed a child to remain in dangerous conditions or engaged in a course of endangering conduct.

J. M. v. Texas Department of Family and Protective Services · filed 2023-01-17(b)(1)(D), (E)

Considering the entire record, we conclude that a reasonable factfinder could form a firm belief or conviction that Father knowingly allowed Child to remain in dangerous conditions and knowingly engaged in a course of endangering conduct himself.

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 endangering conduct.

in the Interest of M.S. · filed 2023-02-02(b)(1)(D), (E)

We conclude that the Department established, by clear and convincing evidence, that Mother and Father committed the predicate acts enumerated in sections 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 exposed a child to endangering conditions or engaged in endangering conduct.

in the Interest of A.C., a Minor Child · filed 2023-02-09(b)(1)(D), (E)

Subsection 161.001(b)(1)(D) allows termination when the evidence proves by clear and convincing evidence that the parent knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endanger the child’s physical or emotional well-being, and subsection 161.001(b)(1)(E) allows termination if the parent has engaged in conduct or knowingly placed the child with persons who engage in conduct which endangers the child’s physical or emotional well-being. ... The evidence was legally and factually sufficient to support termination.

Subsections (D) and (E) permit termination when clear and convincing evidence supports the court’s endangerment findings.

in the Interest of A.C., D.C., and L.C., Children · filed 2023-01-26(b)(1)(D), (E)

We hold that the evidence was legally and factually sufficient to support the termination of Mother’s parental rights under Subsections 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 endangered a child through a threatening environment or a course of conduct.

J. C. v. Texas Department of Family and Protective Services · filed 2023-03-03(b)(1)(D), (E)

Based on this record and the deference we must pay to the factfinder’s determinations related to credibility, the trial court could have found by clear and convincing evidence that Mother had endangered Charles—both by her course of conduct and by placing him in an environment that threatened his well-being: using methamphetamine while pregnant and in his presence during his infancy, engaging in criminal activity that resulted in her incarceration, surrounding herself with others who engage in criminal or violent behavior, and delaying seeking appropriate mental health assistance until the final hearing was underway.

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.H., L.H., and A.H., Children v. the State of Texas · filed 2023-03-07(b)(1)(E)

Considering all the evidence, including disputed evidence, a reasonable factfinder could have formed a firm belief or conviction that Mother engaged in conduct which endangers the physical or emotional well-being of the children.

Section 161.001(b)(1)(D) and (E) require clear and convincing evidence that a parent knowingly exposed a child to endangering conditions or engaged in, or knowingly entrusted the child to someone who engaged in, endangering conduct.

In the Interest of A.Y.C., a Child v. Texas Department of Family and Protective Services · filed 2023-03-09(b)(1)(D), (E)

Considering the evidence in the light most favorable to the trial court’s ruling, we conclude the trial court could have formed a firm belief or conviction that Mother and Father (1) knowingly placed and allowed Adam to remain in conditions or surroundings which endangered his physical or emotional well-being, and (2) engaged in conduct or knowingly placed Adam with persons who engaged in conduct which endangered Adam’s physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) permit termination when a parent knowingly exposes a child to an endangering environment or engages in endangering conduct, including knowingly placing the child with someone whose conduct endangers the child.

M. F. R.-E. v. Texas Department of Family and Protective Services · filed 2023-03-09(b)(1)(D)–(E)

We conclude that this evidence is legally and factually sufficient to support the district court’s finding that Mother knowingly placed or knowingly allowed Daughter to remain in conditions and surroundings which endangered her physical or emotional well-being and its finding that Mother engaged in conduct or knowingly placed Daughter with persons who engaged in conduct which endangered Daughter’s physical or emotional well-being.

Subsections (D) and (E) allow termination for endangerment without proof that a parent’s wrongful act was directed at or actually injured the child.

In the Interest of D.R v. J.I.R., and J.R., Children v. the State of Texas · filed 2023-03-16(b)(1)(D), (b)(1)(E)

As we have explained, DFPS is not required to prove that a parent’s wrongful act was directed at or actually injured the child in question, and as such, it was not required to show E.Y.R. used drugs in the children’s presence.

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

In the Interest of J.M.R.C and J.M.A.C, Children v. Texas Department of Family and Protective Services · filed 2023-03-17(b)(1)(E)

The evidence detailed above was legally and factually sufficient to support termination under subsection E based on Mother’s allegedly engaging in conduct which endangered the physical or emotional well-being of the children.

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

In the Interest of a M., A.C. & C C., Children v. the State of Texas · filed 2023-03-22(b)(1)(D), (E)

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

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 E.G.P. v. the State of Texas · filed 2023-04-13(b)(1)(E)

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

Section 161.001(b)(1)(D) addresses endangering conditions or surroundings, while subsection (E) addresses a parent’s endangering course of conduct.

D. D. and L. H. v. Texas Department of Family and Protective Services · filed 2023-04-27(b)(1)(D), (b)(1)(E)

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

Section 161.001(b)(1)(E) makes a parent’s endangering conduct, or knowing placement of a child with someone engaging in such conduct, a ground for termination.

In the Interest of D. J.G. a Child v. Department of Family and Protective Services · filed 2023-05-18(b)(1)(E)

Accordingly, we hold that the evidence is legally and factually sufficient to support the trial court’s finding that father engaged, or knowingly placed D.J.G. with persons who engaged, in conduct that endangered D.J.G.’s physical and emotional well-being.

Section 161.001(b)(1)(D) and (E) allow termination for an endangering environment or a course of endangering conduct, including abuse or neglect of another child.

In the Interest of I.F.E.-G., Minor Child v. the State of Texas · filed 2023-06-07(b)(1)(D), (E)

We therefore hold the evidence is both legally and factually sufficient to support the trial court’s endangerment finding under subsections (D) and (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 S.C.M., a Child v. Department of Family and Protective Services · filed 2023-06-08(b)(1)(D), (E)

We hold that legally and factually sufficient evidence supports the trial court’s findings that Father committed these statutory predicate grounds for termination of his parental rights to Sarah.

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 through the parent’s course of conduct.

A. P. v. Texas Department of Family and Protective Services · filed 2023-06-13(b)(1)(D), (E)

Viewing the evidence under the applicable standards of review, we conclude that it was legally and factually sufficient to support the endangerment findings against Mother.

Section 161.001(b)(1)(D) and (E) permits termination when clear and convincing evidence shows endangering surroundings or endangering conduct.

In the Interest of H.S. v. the State of Texas · filed 2023-06-15(b)(1)(D), (E)

We determine that the Department established, by clear and convincing evidence, that Mother and Father committed the predicate acts enumerated in subsections 161.001(b)(1)(D) and (E).

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

In the Interest of A.W.A. v. the State of Texas · filed 2023-06-15(b)(1)(D), (E)

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

Subsection (b)(1)(D) addresses conditions that endanger a child, while subsection (b)(1)(E) addresses endangering conduct; either ground requires clear and convincing evidence.

In the Interest of L.J.T., H.G., E.G., J.L., Children v. the State of Texas · filed 2023-06-22(b)(1)(D), (E)

Considering the entire record, including evidence both supporting and contradicting the trial courts findings, we conclude that the contrary evidence is not so overwhelming as to undermine the court’s conviction that Tanya both engaged in conduct that endangered her children’s physical or emotional well-being and knowingly placed or knowingly allowed her children to remain in conditions or surroundings which endangered their physical or emotional well-being.

Subsections (b)(1)(D) and (E) allow termination when a parent endangers a child through the child’s environment or through a course of conduct.

W. G. v. Texas Department of Family and Protective Services · filed 2023-07-07(b)(1)(D), (E)

Based on this record and the deference we must pay to the factfinder’s determinations related to credibility, the associate judge and referring court could have found by clear and convincing evidence that Mother, by her continuing to engage in domestic violence with Father, continuing to maintain that unstable relationship, and failing to attend to her mental health, endangered Derek and Yuri—both by her course of conduct and by placing them in an environment that threatened their well-being.

Section 161.001(b)(1)(D) and (E) allow termination for knowingly exposing a child to endangering conditions or engaging in conduct that endangers the child.

In the Interest of S.N.B v. the State of Texas · filed 2023-07-27(b)(1)(D), (E)

We hold the evidence is legally and factually sufficient to support the predicate termination findings 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 allowed a child to remain in endangering surroundings or engaged in endangering conduct.

In the Interest of A. E., a Child v. the State of Texas · filed 2023-07-31(b)(1)(D), (b)(1)(E)

Based on the foregoing, we hold that the evidence is legally and factually sufficient to support the trial court’s judgment terminating J.E.’s parental rights to A.E under subsections (D) and (E).

Subsections (b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent exposed children to endangering conditions or conduct, including by failing to protect them from a known risk of sexual abuse.

In the Interest of A.F., D.F., D.F., A.O., and D.O. v. the State of Texas · filed 2023-08-03(b)(1)(D), (E)

We conclude the evidence is legally and factually sufficient to support the trial court’s finding that the Department established by clear ... and convincing evidence that Mother committed the predicate acts enumerated in subsections D and E.

Subsections (b)(1)(D) and (E) provide termination grounds when a parent knowingly exposes a child to endangering surroundings or engages in endangering conduct or knowingly places the child with someone who does.

A. R. v. Texas Department of Family and Protective Services · filed 2023-08-11(b)(1)(D)–(E)

We conclude that this evidence is legally and factually sufficient to support the district court’s finding that Mother knowingly placed or knowingly allowed the children to remain in conditions and surroundings which endangered their physical or emotional well-being and its finding that Mother engaged in conduct or knowingly placed the children with persons who engaged in conduct which endangered their physical or emotional well-being. See Tex. Fam. Code § 161.001(b)(1)(D)–(E).

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

In the Interest of J.S., a Child v. the State of Texas · filed 2023-09-06(b)(1)(D)

Considering all the evidence, we conclude the evidence is both legally and factually sufficient to produce in the minds of the jurors a firm belief or conviction as to the truth of the allegation that Mother knowingly placed or knowingly allowed J.S. to remain in conditions or surroundings which endangered his physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) permit termination when a parent endangers a child by exposing the child to a partner whose drug use and violence pose known risks.

In the Interest of B.U., a Child v. the State of Texas · filed 2023-09-14(b)(1)(D), (E)

Applying the standards articulated above, we conclude that legally sufficient evidence supports the trial court’s findings under Subsections (D) and (E) that Mother endangered B.U. See Tex. Fam. Code Ann. § 161.001(b)(1)(D), (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 conditions or engaged in conduct that endangered the child.

In the Interest of C.G.G. v. the State of Texas · filed 2023-09-21(b)(1)(D), (E)

Therefore, 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 Mother knowingly placed or knowingly allowed Cade to remain in conditions or surroundings which endangered his physical or emotional well-being and engaged in conduct or knowingly placed Cade with persons who engaged in conduct that endangered his physical or emotional well-being.

Repeated incarceration can support a finding of endangerment by conduct when it exposes a child to instability and the risk of being left without a caregiver.

In the Interest of E.J., B.J., K.C. and K.C., Children v. the State of Texas · filed 2023-10-05(b)(1)(E)

Given Father’s extensive history of incarceration and viewed in the light most favorable to its endangerment-by-conduct finding, we hold that a reasonable factfinder could form a firm belief or conviction that the finding is true. We also conclude, having performed an exacting review of the entire record, that the evidence is factually sufficient to support the trial court’s endangerment-by-conduct finding.

Incarceration alone does not establish endangerment under subsection (b)(1)(E), but a course of criminal conduct and incarceration can support termination when it endangers the child’s physical or emotional well-being.

In the Interest of K.M.H., a Child v. Department of Family and Protective Services · filed 2023-10-12(b)(1)(E)

Standing alone, a parent’s mere incarceration will not satisfy the predicate ground for endangerment, but if the evidence as a whole—including the incarceration—shows a course of conduct that has the effect of endangering the physical or emotional well-being of a child, then a finding under the predicate ground is supportable.

A parent’s drug use supports termination for endangerment by conduct when it is causally linked to danger to the child.

In the Interest of S.D.H.B., A/K/A S.H., A.N.H., A/K/A A.H., M.E.R.B., A/K/A M.S., M.M.R., A/ka M.R. v. Department of Fa · filed 2023-11-02(b)(1)(E)

As we have previously explained, to be relevant to this analysis, there must be a causal link between a parent’s drug use and the endangerment to the child. ... The evidence was legally and factually sufficient to establish such a link in this case.

A parent’s voluntary course of conduct can support termination under subsection (E) when it endangers the child’s physical or emotional well-being.

In the Interest of C.K.C., a Child v. the State of Texas · filed 2023-12-28(b)(1)(E)

Accordingly, this evidence is legally and factually sufficient to support the trial court’s finding that Mother engaged in a pattern of conduct that endangered Christy’s physical or emotional well-being.

Under subsections (D) and (E), endangering conduct toward one child can support termination as to other children even if the conduct was not directed at them and they suffered no injury.

In the Interest of C.D.M., J.L.M., and H.N.P., Children v. the State of Texas · filed 2023-10-31(b)(1)(D), (b)(1)(E)

Though most of the parents’ acts and omissions put forth by the Department relate directly to J., this does not make the evidence insufficient as to Father’s parent- child relationship with C. or H. because, as stated above, “it is not necessary that the conduct be directed at the child or that the child actually suffer an injury.”

Drug use during pregnancy can support termination under subsections (D) and (E) when it endangers the children through their surroundings and the parent's conduct.

Baby Girl H., a Child v. the State of Texas · filed 2023-11-13(b)(1)(D), (E)

Based on the record in this case, a reasonable factfinder could have resolved the disputed facts related to Mother’s drug use by finding that the evidence showed that she used drugs while pregnant and that this use endangered her children 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; repeated exposure to domestic violence can support that finding.

O.G.M. v. Department of Family and Protective Services · filed 2023-12-07(b)(1)(E)

We conclude that the evidence was legally sufficient to support termination under subsection (E); we also conclude the evidence was not factually insufficient to support termination under subsection (E).

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

In the Interest of S.D.T., a Child v. the State of Texas · filed 2023-12-13(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 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; drug use, unsafe living conditions, educational neglect, and refusal to participate in services can support that finding.

T. D. v. Texas Department of Family and Protective Services · filed 2024-01-26(b)(1)(E)

Paragraph (E) applies when 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 § 161.001(b)(1)(E). ... In all then, under the applicable legal- and factual-sufficiency standards, we conclude that the evidence was sufficient to support termination under Paragraph (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 P.D.H., K.R.H., and T.H., Children v. the State of Texas · filed 2024-02-05(b)(1)(E)

From the above-recited evidence, we conclude that the record firmly established that Mother engaged in a course of conduct that endangered the children’s physical and emotional well-being. As a result, we find that legally and factually sufficient evidence supported the trial court’s finding under ground E.

Section 161.001(b)(1)(E) permits termination when clear and convincing evidence shows that a parent endangered a child through the parent’s conduct or knowingly placed the child with someone whose conduct endangered the child.

In the Interest of K.G., a Child v. the State of Texas · filed 2024-02-28(b)(1)(E)

The trial court’s finding that clear and convincing evidence supported termination under subsection (E) is supported by legally and factually sufficient evidence.