Tex. Fam. Code Ann. § 161.001

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

In the Interest of P.M. and A.M., Children v. the State of Texas · filed 2024-03-07(b)(1)(E)

Subsection (E) requires a voluntary, deliberate, and conscious course of conduct rather than a single act or omission.

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

In Re K.H.G., a Child v. the State of Texas · filed 2024-03-14(b)(1)(E)

We therefore hold that the evidence was legally sufficient to support termination of Mother’s parental rights under predicate ground (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, missed visits, and failure to complete services can support that finding.

In the Interest of A.V.G.-P. and A.O.G.-P., Children v. the State of Texas · filed 2024-03-28(b)(1)(E)

Viewing the evidence under the appropriate standards for the legal and factual sufficiency of the evidence, the evidence was legally and factually sufficient to sustain the trial court's endangerment finding pursuant to Subsection (E).

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

In the Interest of J.S., A.B., H.O., and C.O., Children v. the State of Texas · filed 2024-03-28(b)(1)(E)

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

Evidence of sexual abuse and violent behavior can support endangerment findings under subsections (D) and (E).

In the Interest of A.D., I.D., and A.D., Children v. the State of Texas · filed 2024-01-11(b)(1)(D), (E)

Because it is undisputed that evidence of sexual abuse and a propensity toward violent behavior support a finding of endangerment, the evidence was 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 a parent knowingly exposes children to an endangering environment or engages in conduct that endangers their physical or emotional well-being.

In the Interest of P.P.-S., and G.P.-S., Children v. the State of Texas · filed 2024-01-11(b)(1)(D), (b)(1)(E)

Viewing all the evidence in the light most favorable to the trial court’s judgment and giving due deference to the factfinder’s endangerment findings, we hold that a factfinder 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 endangered their emotional or physical well-being and that Mother had engaged in conduct or knowingly placed the children with others whose conduct endangered their physical or emotional well-being.

Subsections (D) and (E) permit endangerment findings when a parent knowingly leaves children with a dangerous caregiver and continues a relationship with that caregiver after the abuse.

S. S. v. Texas Department of Family and Protective Services · filed 2024-01-12(b)(1)(D), (E)

Further, the trial court reasonably could have credited the undisputed evidence of Zane’s extensive injuries, the testimony of Grandmother, and admissions by Mother to find that Mother was aware that Father posed a danger and risk to the children’s well-being when she left them in his care. ... 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) permit termination when a parent knowingly exposes a child to endangering conditions or engages in endangering conduct, including knowingly placing the child with someone whose conduct endangers the child.

In the Interest of Z.K.R., a Child v. the State of Texas · filed 2024-03-28(b)(1)(D), (E)

The trial court’s subsection (D) and (E) findings are adequately supported by the evidence in the record.

Section 161.001(b)(1)(E) permits termination when a parent’s conduct or knowing placement of a child with an endangering person threatens the child’s physical or emotional well-being.

In the Interest of A.T., Jr., Children v. the State of Texas · filed 2024-01-10(b)(1)(E)

After reviewing the evidence under the appropriate standards of review, we conclude that a factfinder could reasonably have formed a firm belief or conviction that M.R. engaged in conduct (e.g., prolonged illegal drug use, including during her pregnancy with S.M.M.M.) or knowingly placed the children with persons who engaged in conduct (e.g., allowing Jarek O.K. to remain in the home after allegations that he sexually abused V.C.M.R.) which endangers the physical or emotional well-being of the children.

Section 161.001(b)(1)(D) and (E) permit termination when a parent knowingly exposes a child to endangering conditions or engages in endangering conduct.

In the Interest of D.W., A.W., I.W., I.W., Children v. the State of Texas · filed 2024-01-29(b)(1)(D), (E)

Considering the entire record, including evidence both supporting and contradicting the trial court’s findings, we conclude that the contrary evidence is not so overwhelming as to undermine the court’s finding that Mother 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.

Section 161.001(b)(1)(D) concerns an environment that endangers a child, while (E) concerns parental conduct that directly endangers a child.

In the Interest of C.W., a Child v. the State of Texas · filed 2024-02-15(b)(1)(D)–(E)

Under Subsection 161.001(b)(1)(D), we examine evidence about the child’s environment to determine if the environment caused the physical or emotional endangerment. ... 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 a parent’s deliberate course of conduct endangers a child’s physical or emotional well-being; physical abuse of one child can endanger other children in the home.

In the Interest of A.R., and N.R., Children v. the State of Texas · filed 2024-02-06(b)(1)(E)

Based on the foregoing analysis, the evidence was legally and factually sufficient to support the trial court’s predicate finding of endangerment under section E. See Tex. Fam. Code § 161.001(b)(1)(E).

Section 161.001(b)(1)(D) and (E) permits termination when clear and convincing evidence shows that a parent endangered children through their living conditions or conduct.

In the Interest of S. M. C. and L. M. C., Children v. the State of Texas · filed 2024-02-07(b)(1)(D) and (E)

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

Section 161.001(b)(1)(M) permits termination when a parent’s rights to another child were previously terminated on endangerment grounds.

In the Interest of O.P.-W. Jr. and A. O. P.-W., Children v. Department of Family and Protective Services · filed 2024-03-19(b)(1)(M)

This undisputed evidence, standing alone, is legally and factually sufficient as a matter of law to support the trial court’s finding that Mother engaged in the predicate ground for the termination of her rights as to Jayla and Pia under Section 161.001(b)(1)(M).

Pervasive illegal drug use can support a finding that a parent engaged in conduct endangering a child under subsection (b)(1)(E).

In the Interest of K.B., Child v. Department of Family and Protective Services · filed 2024-02-27(b)(1)(E)

The evidence establishes that Father’s drug use was so pervasive and serious that the factfinder could reasonably infer that it was endangering. ... We hold that the evidence is legally and factually sufficient to support the predicate termination finding under subsection (E).

Section 161.001(b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being; proof that the parent caused a specific injury is unnecessary.

In THE INTEREST OF C.E., a CHILD v. the State of Texas · filed 2024-03-01(b)(1)(E)

And termination under (E) requires that a parent’s conduct endanger the child’s physical or emotional well-being. Proof that a parent specifically caused an injury is not necessary.

Subsection (b)(1)(E) allows termination when a parent’s course of conduct endangers a child’s physical or emotional well-being, including through continued drug use.

In the Interest of I. C., a Child v. the State of Texas · filed 2024-04-10(b)(1)(E)

Because we hold there is sufficient evidence that Lindsey endangered Ivy’s well-being through her course of conduct, see TEX. FAM. CODE ANN. § 161.001(b)(1)(E), we consider only statutory ground (E).

Section 161.001(b)(1)(E) permits termination when a parent’s drug use and repeated conduct leading to incarceration endanger a child, even if the conduct occurs outside the child’s presence.

A. S. v. Texas Department of Family and Protective Services · filed 2024-04-12(b)(1)(E)

Father’s illegal-drug use and repeated conduct leading to incarceration still exposed Child to jeopardy and loss even if Father did not do those things while around Child.

Section 161.001(b)(1)(E) allows persistent drug use and related incarceration to support an endangerment finding.

In the Interest of C.J.B., a Child v. the State of Texas · filed 2024-05-16(b)(1)(E)

Father’s persistent drug use and repeated drug-related incarceration exposes C.J.B. to a life of uncertainty and instability and supports a finding under Subsection E.

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

In the Interest of C.H. and I.P., Children v. the State of Texas · filed 2024-06-06(b)(1)(E)

Under the facts of this case, viewing the evidence under the appropriate standards for legal and factual sufficiency of the evidence, the trial court did not err in its finding that the mother engaged in endangering conduct or allowed the children to remain in a home with a person who engaged in endangering conduct 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; conduct after the child’s removal may support that finding.

In Re I.J.S and B.K.S., Children v. the State of Texas · filed 2024-06-20(b)(1)(E)

Therefore, we hold the evidence is also factually sufficient to support the trial court’s finding under subsection (E).

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

In the Interest of K.O. and K.Q., Children v. the State of Texas · filed 2024-06-26(b)(1)(E)

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

A parent’s pattern of drug abuse can support an endangerment finding under subsections (D) and (E) without proof that the child suffered an actual injury.

In the Interest of H.R.S. v. the State of Texas · filed 2024-04-04(b)(1)(D), (E)

In our opinion, there is ample evidence in this record to support the trial court’s subsection D and E findings. A pattern of drug abuse will support a finding of conduct endangering a child under subsection D or E even if there is no evidence that such drug use caused a physical or actual injury to the child.

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

In the Interest of A.R.D., a Child v. the State of Texas · filed 2024-04-18(b)(1)(E)

Viewing the evidence in the light most favorable to Mother, we conclude that the evidence is legally sufficient to support the trial court’s finding of endangerment under section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) permits an endangerment finding when a parent neglects to seek medical help for a child in medical distress.

In the Interest of K.A.G., a Child v. Department of Family and Protective Services · filed 2024-05-21(b)(1)(E)

Based on the other evidence already discussed above, a reasonable factfinder could have formed a firm belief that, at the very least, the Father endangered the Child by neglecting to seek medical help on two occasions when the Child was in medical distress.

Subsection (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 E.J. and R.J., Children v. the State of Texas · filed 2024-05-02(b)(1)(E)

Considering all the evidence in the light most favorable to the trial court’s finding and considering the evidence as a whole, we conclude the evidence is legally and factually sufficient to support the trial court’s determination that Father violated subsection 161.001(b)(1)(E).

Section 161.001(b)(1)(E) permits a conduct-based endangerment finding based on a continuing course of conduct, including earlier acts that remain relevant to the parent’s behavior at trial.

In the Interest of N.T. and K.C., Children v. the State of Texas · filed 2024-05-09(b)(1)(E)

In sum, whether viewing the evidence in a light most favorable to the verdict or considering the disputed evidence based on the record as a whole, a reasonable jury could have formed a firm belief or conviction that Mother had engaged in an endangering course of conduct both while the Children were in her care and afterward. The jury’s statutory predicate findings of endangering conduct were thus supported by legally and factually sufficient evidence.

Section 161.001(b)(1)(E) allows abuse of a sibling before a child’s birth to support an endangerment finding when the conduct shows an ongoing risk to the child.

In the Interest of M.F.M., a Child v. the State of Texas · filed 2024-06-25(b)(1)(E)

Although this abuse occurred prior to Mike’s birth, the trial court reasonably could infer from the parents’ past conduct that the violent behavior and inability to protect the children from the other parent would continue in the future.

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

In the Interest of C.M. and D.M., Children v. the State of Texas · filed 2024-06-27(b)(1)(E)

On this record, we conclude that there is legally and factually sufficient evidence to support the trial court’s finding that Appellant engaged in a continuing course of conduct that endangered the physical or emotional well-being of her children. See FAM. § 161.001(b)(1)(E).

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

In the Interest of K.W., a Child v. the State of Texas · filed 2024-07-18(b)(1)(E)

Giving due deference to the trial court’s findings, without supplanting its judgment with our own, and after viewing the entire record, we hold that the evidence is legally and factually sufficient to show that Mother engaged in a course of conduct that endangered K.W.’s physical or emotional well-being.

Section 161.001(b)(1)(E) permits termination when a parent's continued drug use and failure to participate in drug counseling form a course of conduct that endangers a child's physical or emotional well-being.

In the Interest of J.A.R., a Child v. Department of Family and Protective Services · filed 2024-07-22(b)(1)(E)

Viewing this evidence in the light most favorable to the trial court’s finding, we conclude that a factfinder could have reasonably found that Mother and Father’s continued drug use and failure to participate in drug counseling constituted a course of conduct that endangered the emotional or physical well- being of J.A.R.

Subsection (b)(1)(E) permits termination when a parent’s ongoing illegal drug use constitutes a course of conduct that endangers the child’s physical or emotional well-being.

K. B. v. Texas Department of Family and Protective Services · filed 2024-08-22(b)(1)(E)

After considering all the evidence in the light most favorable to the jury’s finding, along with any undisputed evidence contrary to the finding under subsection (E), we conclude that a reasonable factfinder could have formed a firm belief or conviction that Mother’s illegal drug use constitutes a course of conduct that endangered Kevin’s physical or emotional well-being.

A parent’s denial of behavioral problems and failure to address them can support a finding of endangering conduct under subsection (E).

J. B. v. Texas Department of Family and Protective Services · filed 2024-08-23(b)(1)(E)

Thus, the trial court could have found Mother’s denial of her behavioral problems and lack of effort to change them during the pendency of the case to be endangering conduct.

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 R.G., a Child v. the State of Texas · filed 2024-09-11(b)(1)(E)

Based on the testimony at trial, the trial court could find, by clear and convincing evidence, that both Mother and Father engaged in a course of conduct that endangered Raynese’s physical well-being.

Section 161.001(b)(1)(E) makes a parent's conduct that endangers a child's physical or emotional well-being a ground for termination; drug use may establish that ground.

In the Interest of K.E.S., K.Y.S., and K.A.S., Children v. the State of Texas · filed 2024-09-12(b)(1)(E)

Considering the foregoing, we conclude that the evidence is legally and factually sufficient to establish that C.S. engaged in conduct that endangered the physical or emotional well-being of K.E.S, K.Y.S, and K.A.S.

Section 161.001(b)(1)(E)’s endangering-conduct ground can be established by a voluntary course of conduct that jeopardizes a child’s well-being, without proof of actual harm or direct exposure while the child is in the parent’s care.

In the Interest of A.M., a Child v. the State of Texas · filed 2024-09-12(b)(1)(E)

Applying the standards of review set forth above, we hold that the evidence is legally and factually sufficient to support the endangering-conduct finding.

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 L.G.B., a Child v. the State of Texas · filed 2024-09-19(b)(1)(E)

Based upon the evidence presented at trial, the trial court could have reasonably found by clear and convincing evidence that the father engaged in a course of conduct that would endanger the well-being of L.G.B.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child; repeated drug use and missed drug tests can support that finding.

L. C. v. Texas Department of Family and Protective Services · filed 2024-10-03(b)(1)(E)

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

Section 161.001(b)(1)(E) permits termination when a parent’s failure to protect children from known sexual abuse forms an endangering course of conduct proved by clear and convincing evidence.

In the Interest of B.B., C.B., and J.B., Children v. the State of Texas · filed 2024-10-09(b)(1)(E)

Based on the testimony at trial, the trial court could find, by clear and convincing evidence, that Mother engaged in a course of conduct that endangered the children’s physical well-being. Mother endangered B.B., C.B., and J.B. by being aware of and yet not protecting them from sexual abuse by each other and by Father.

Section 161.001(b)(1)(E) permits termination when a parent’s conduct endangers a child, including when the parent fails to protect the child from another caregiver’s abuse.

In the Interest of M. Children v. Department of Family and Protective Services · filed 2024-11-14(b)(1)(E)

From the evidence, the trial court could reasonably conclude that Father either physically abused Michael and Evan or failed to protect them from Mother’s abuse, resulting in serious injuries to both 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; repeated criminal conduct and incarceration can support that finding.

In the Interest of A.S.R. AKA A.R., a Child v. the State of Texas · filed 2024-11-21(b)(1)(E)

Accordingly, we conclude that the evidence is legally and factually sufficient to support the trial court’s finding under predicate ground (E).

Subsection (b)(1)(E) permits evidence of events from years earlier to establish the voluntary, deliberate, and conscious course of endangering conduct required for termination.

In the Interest of J.D., J.D., E.R., M.R., and G.R., Children v. the State of Texas · filed 2025-01-09(b)(1)(E)

Moreover, despite Mother’s protest against the use of prior history, she cites nothing to support her argument, and the Department was permitted to put on evidence of events that had occurred years earlier to meet Subsection (E)’s requirement of showing that there was a “voluntary, deliberate, and conscious course of conduct.”

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.

A. S. v. Texas Department of Family and Protective Services · filed 2025-01-09(b)(1)(E)

Viewing the totality of this evidence in the light most favorable to the finding, we conclude that a reasonable factfinder could form a firm belief or conviction that Mother engaged in a course of conduct that endangered Dylan’s physical and emotional well-being.

Section 161.001(b)(1)(E) permits an endangering conduct finding based on a parent’s repeated drug use during pregnancy and while a termination case is pending.

In the Interest of L.O.A., G.A., III, and M.E.A., Children v. the State of Texas · filed 2025-01-22(b)(1)(E)

Mother continued to use drugs while pregnant with L.A. and tested positive for amphetamines and marijuana at the birth of L.A., one month after being sentenced for the possession of a controlled substance. ... Then, during the Department’s current case against Mother, she tested positive for marijuana on April 25, 2023. ... On this record, a reasonable factfinder could have formed a firm belief or conviction of endangerment.

Section 161.001(b)(1)(E) permits termination when a parent’s own conduct endangers a child’s physical or emotional well-being, even if the parent did not know about other dangers surrounding the child.

In the Interest of I.P. and R.P., Children v. the State of Texas · filed 2025-01-23(b)(1)(E)

Viewing the evidence under the appropriate standards, the evidence was legally and factually sufficient for the trial court to have found that the father had engaged in conduct which endangered the physical or emotional well-being of I.P. pursuant to Section 161.001(b)(1)(E).

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

In the Interest of C.M., K.N., and R.M., Children v. the State of Texas · filed 2025-02-06(b)(1)(E)

Considering the foregoing, we conclude that the evidence was legally and factually sufficient to establish that Father and Mother engaged in conduct that endangered the physical or emotional well-being of the children. 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 endangers a child’s physical or emotional well-being; missed drug tests and unstable housing can support that finding.

M. R. and J. L. III v. Texas Department of Family and Protective Services · filed 2025-02-07(b)(1)(E)

We conclude that the unobjected-to evidence is legally and factually sufficient to support the trial court’s termination of Father’s and Mother’s parental rights under Subsection (E).

Section 161.001(b)(1)(E) permits termination for a voluntary, deliberate course of conduct that endangers a child, even if the child suffers no actual injury.

In the Interest of A v. and A.R., Children v. the State of Texas · filed 2025-02-19(b)(1)(E)

Nevertheless, she continued to engage in a voluntary, deliberate, and conscious course of conduct posing a potential risk of danger to her children. Actual injury to the children was not required; rather, they were exposed to the possibility that A.J. could be impaired or imprisoned from her voluntary conduct.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct endangers a child; repeated drug use and incarceration can support that finding without proof of actual harm.

In the Interest of A. N. a Child v. Department of Family and Protective Services · filed 2025-02-25(b)(1)(E)

We therefore hold that factually sufficient evidence supports the trial court’s finding that termination of Mother’s parental rights to Anna was warranted 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, including drug use accompanied by circumstances showing a risk of harm.

In the Interest of J. L. Jr., a Child v. Department of Family and Protective Services · filed 2025-03-11(b)(1)(E)

We therefore hold that the evidence was legally sufficient to support termination of Father’s parental rights under Subsection (E).

Subsection (b)(1)(E) permits termination when a parent’s conduct endangers a child’s physical or emotional well-being, including repeated exposure to a registered sex offender.

In the Interest of A.D.H., M.M.H., and A.I.M.W., Children v. the State of Texas · filed 2025-03-13(b)(1)(E)

We conclude that the evidence was legally and factually sufficient to support termination of Mother’s parental rights to all three children under Subsection E. See TEX. FAM. CODE ANN. § 161.001(b)(1)(E).

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

In the Interest of B.S. and R.S., Children v. the State of Texas · filed 2025-03-27(b)(1)(E)

Considering the foregoing, we conclude that the evidence was legally and factually sufficient to establish that Mother engaged in conduct that endangered the physical or emotional well-being of the children.

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

C. C. v. Texas Department of Family and Protective Services · filed 2025-03-31(b)(1)(E)

Thus, the evidence is legally and factually sufficient to support the trial court’s termination of Mother’s parental rights under subsection (E), see Tex. Fam. Code § 161.001(b)(1)(E), and we overrule her appellate issues contending otherwise.

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.R Jr. and J.R., Children v. the State of Texas · filed 2025-05-01(b)(1)(E)

While Father again did not differentiate between legal and factual sufficiency, we nonetheless conclude the evidence is both legally and factually sufficient to support termination under Subsection (E).

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

C. M. v. Texas Department of Family and Protective Services · filed 2025-05-23(b)(1)(E)

We conclude that Father’s previous actions demonstrate a voluntary, deliberate, and conscious course of conduct that endangered Ben’s physical or emotional well-being and thus the evidence was legally and factually sufficient to support termination under subsection (E).

Subsection 161.001(b)(1)(E) supports termination when the evidence establishes a parent’s endangering conduct.

In the Interest of E.W., J.S, M.D., and L.P., Children v. the State of Texas · filed 2025-06-05(b)(1)(E)

In light of the foregoing, we conclude that the evidence is sufficient to establish that each appellant violated subsection 161.001(b)(1)(E).

Section 161.001(b)(1)(E) permits termination for conduct that endangers a child’s physical or emotional well-being; persistent prenatal drug use and failure to visit can support that ground.

In the Interest of Z.R., a Child v. the State of Texas · filed 2025-06-09(b)(1)(E)

Mother’s persistent drug use during pregnancy and failure to regularly visit Z.R. clearly support the trial court’s endangering-course-of-conduct finding. After reviewing the evidence in the light most favorable to the verdict and in a neutral light, we hold that legally and factually sufficient evidence supports the trial court’s predicate ground (E) finding.

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 conditions or engaged in endangering conduct.

In the Interest of K.H., a Child v. the State of Texas · filed 2025-03-13(b)(1)(D), (E)

Considering the entire record, we conclude that the trial court could have formed a firm belief or conviction that C.S. both knowingly allowed her child to remain in conditions or surroundings which endangered his physical or emotional well-being, and engaged in conduct or knowingly placed her child with persons who engaged in conduct which endangered his physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) permit termination when a parent’s repeated failure to protect children from domestic violence creates an endangering environment and constitutes endangering conduct.

B. C. and J. G. F. v. Texas Department of Family and Protective Services · filed 2025-04-11(b)(1)(D), (E)

We conclude that this evidence of Mother’s repeated assaults, and Father’s failure to remove himself and his children from that violent relationship supports the endangerment finding under Subsection D. ... This evidence also shows a course of endangering conduct, which supports termination under Subsection E.

Section 161.001(b)(1)(D) and (E) permit endangerment findings when parental drug use and the risk of exposure to violence show a continuing substantial risk of harm to children.

In the Interest of Z. J. G., J. R. G. and N. L. G. v. Department of Family and Protective Services · filed 2025-04-17(b)(1)(D), (E)

The trial court could reasonably have interpreted the above evidence regarding the risk of Mother and Father exposing the children to drugs and violence as showing a pattern of continued substantial risk of harm to the children sufficient to support its finding of endangerment under subsections (D) and (E).

Section 161.001(b)(1)(E) generally requires a course of endangering conduct rather than one individual act.

In the Interest of C.E., a Child v. the State of Texas · filed 2025-04-24(b)(1)(E)

Termination under Subsection (E) generally requires a course of conduct rather than one individual act.

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

Isam v. Isam · filed 2025-04-25(b)(1)(E)

We overrule Matthew’s challenge to the endangerment finding under subsection (E) and do not address his challenges to the findings of grounds for termination under subsections (C) and (F).

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

In the Interest of E.M. & A. M., Children v. the State of Texas · filed 2025-04-30(b)(1)(E)

Based on the foregoing, we conclude that the evidence is sufficiently clear and convincing such that a reasonable factfinder could have formed a firm conviction or belief that Appellant engaged in conduct or knowingly placed the children with persons who engaged in conduct that endangered the physical or emotional well-being of the child.

Under subsection (b)(1)(E), a parent's delusions and failure to obtain mental health treatment can support a finding that the parent endangered a child's physical or emotional well-being.

In the Interest of S.D.T. and S.D.T. v. the State of Texas · filed 2025-05-01(b)(1)(E)

Mother’s delusions and failure to receive treatment for her mental health can endanger the physical and emotional welfare of the children. ... Having determined that the evidence is legally and factually sufficient to support predicate endangerment findings under subsection (E), we need not address whether the evidence would also support the trial court’s predicate findings of one or more of subsections (N) or (O), the remaining predicate findings that Mother challenged in her brief.

Section 161.001(b)(1)(D) and (E) provide grounds for termination when the evidence establishes an endangering environment or endangering parental conduct.

R. C. and H. C. v. Texas Department of Family and Protective Services and A. R. · filed 2025-05-08(b)(1)(D), (b)(1)(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. See Tex. Fam. Code § 161.001(b)(1)(D), (E); In re A.C., 560 S.W.3d at 630–31.

Subsections (b)(1)(D) and (E) allow termination when clear and convincing evidence shows that a parent endangered a child through the child’s environment and a course of conduct.

In the Interest of K.J., a Child v. the State of Texas · filed 2025-06-05(b)(1)(D), (E)

We thus hold that the evidence is both legally and factually sufficient to support the trial court’s findings of statutory grounds under subsections (D) and (E) for Mother and Father.

Section 161.001(b)(1)(E) permits a court to consider a parent’s conduct before the child’s birth and after the child’s removal when deciding whether the parent endangered the child.

In the Interest of A.C.K. AKA A.K., a Child v. Department of Family and Protective Services · filed 2025-06-24(b)(1)(E)

Under subsection (E), our review is not limited to Mother’s actions that occurred in between Amelia’s birth and removal. We may consider conduct that occurred after Amelia’s removal, such as Mother’s continued alcohol usage and her additional criminal history. We may also consider conduct that occurred before Amelia’s birth, such as Mother’s criminal history dating back to 2009, her history with Montana CFS relating to Anna, and the May 2022 endangering a child incident, which occurred while Mother was pregnant with Amelia. ... We hold that legally and factually sufficient evidence supports the jury’s subsection (E) 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, including conduct outside the child’s presence.

In the Interest of K.W., a Child v. the State of Texas · filed 2025-06-26(b)(1)(E)

We find that the evidence presented at trial was legally and factually sufficient to support a finding that Father engaged in a course of conduct that endangered the physical or emotional well-being of the children. See TEX. FAM. CODE ANN. § 161.001(b)(1)(E).

Subsection (b)(1)(E) provides a predicate 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 A.R.G., a Child v. the State of Texas · filed 2025-06-26(b)(1)(E)

Considering the foregoing, we conclude that the evidence was legally and factually sufficient to establish that Mother engaged in conduct that endangered the physical or emotional well-being of A.R.G. See TEX. FAM. CODE ANN. § 161.001(b)(1)(E).

Subsection (b)(1)(E) permits termination when clear and convincing evidence shows that a parent’s conduct, including failures to act, endangered a child’s physical or emotional well-being.

In the Interest of A.K., E.K., E.K., J.K., D.K., and D.K., Children v. the State of Texas · filed 2025-08-14(b)(1)(E)

Considering all the evidence presented in this case in the light most favorable to the trial court’s finding and considering the evidence as a whole, we conclude that the evidence was legally and factually sufficient to establish that Father engaged in conduct that endangered the physical or emotional well-being of the children. See TEX. FAM. CODE ANN. § 161.001(b)(1)(E).

Subsections (b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent’s conduct or knowingly allowed conditions endangered a child’s physical or emotional well-being.

In the Interest of S. A. H., a Minor Child v. the State of Texas · filed 2025-06-12(b)(1)(D), (E)

Based on the foregoing and giving due deference to the trial court’s findings, we conclude that the trial court could have formed a firm belief or conviction that Mother engaged in conduct or knowingly allowed Linda to remain in conditions or surroundings which endangered Linda’s physical or emotional well-being.

Section 161.001(b)(1)(E) allows a finding of endangerment when a parent’s pattern of conduct presents a substantial risk of harm to the child, even without direct harm.

In the Interest of N.L.S. and E.J.C. A/K/A E.J.C., Children · filed 2025-06-13(b)(1)(E)

Accordingly, we confirm that endangerment under Subsection (E), as under Subsection (P), “does not require [the parent’s conduct] to directly harm the child.”

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

In the Interest of N. N. J., a Child v. the State of Texas · filed 2025-06-18(b)(1)(D), (E)

Viewing all the evidence in the light most favorable to the trial court’s (D) and (E) findings and considering undisputed contrary evidence, we conclude that a reasonable factfinder could form a firm belief or conviction that the findings were true.

Section 161.001(b)(1)(E) permits termination when a parent’s course of conduct creates a potential danger to the child that the parent knows of but disregards.

In the Interest of A.D.M. Jr., a Child v. the State of Texas · filed 2025-06-18(b)(1)(E)

Any portion of the evidence described above may not be sufficient to support a subsection (E) finding if considered in isolation. However, when viewed as a whole and in the light most favorable to the judgment, the evidence was sufficient to allow the trial court to form a firm belief or conviction that Mother engaged in a course of conduct that created a potential for danger which she was aware of but disregarded.

Section 161.001(b)(1)(D) and (E) allow termination when the evidence establishes an endangering environment and a continuing course of endangering conduct.

In the Interest of D.S., D.S., D.S., and D.B., Children v. the State of Texas · filed 2025-06-19(b)(1)(D), (E)

Applying the standards of review set forth above, we hold that the evidence is legally and factually sufficient to support the endangerment findings under Subsections (D) and (E).

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

In the Interest of L.M. v. the State of Texas · filed 2025-06-26(b)(1)(D), (E)

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

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

In the Interest of S.F.E.J, A.M.L.E., E.S.H.F.E., A.D.C.F.E., L.L.R.F.E., Children v. the State of Texas · filed 2025-07-02(b)(1)(D), (E)

Further, after considering the entire record, including any disputed or contrary evidence, we conclude that the evidence is factually sufficient to support the trial court’s termination under subsections (D) and (E) of the Texas Family Code.

Section 161.001(b)(1)(D) and (E) allow termination when clear and convincing evidence shows that a parent knowingly left children in an endangering environment or engaged in endangering conduct.

In the Interest of Y.R. and N.G., Children v. the State of Texas · filed 2025-07-24(b)(1)(D), (E)

V.G.’s testimony alone, which the trial court was entitled to credit, established that Appellant engaged in endangering conduct and knowingly allowed the children to remain in an endangering environment.

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 surroundings or the parent's conduct.

In the Interest of C.C., a Child v. the State of Texas · filed 2025-07-30(b)(1)(D), (E)

After viewing all the evidence in the light most favorable to the grounds D and E findings, we conclude that the trial court could have reasonably formed a firm belief or conviction that the Department proved the requisites for terminating Mother’s parental rights under statutory grounds D and E.

A parent’s drug use, domestic violence, and failure to maintain a safe home can support an endangerment finding under § 161.001(b)(1)(E).

In the Interest of J.N.R., L.A.A.M., K.E.M., and K.J-A.M., Children v. the State of Texas · filed 2025-08-06(b)(1)(E)

Here, the uncontroverted evidence establishes that Mother used methamphetamine and marijuana and that she engaged in domestic violence. In addition, Mother did not maintain a home that was safe or stable for her children. ... We hold the evidence is legally sufficient to support the trial court’s endangerment finding under subsection (E). We also hold that the contrary disputed evidence is not “so significant that a factfinder could not reasonably have formed a firm belief or conviction,” and thus the evidence is factually sufficient.

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

In the Interest of G.G., G.R., G.G., and G.G., Children v. the State of Texas · filed 2025-08-18(b)(1)(D), (b)(1)(E)

Based on the testimony at trial, the trial court could find, by clear and convincing evidence, that Mother engaged in a course of conduct that endangered the children’s physical and emotional well-being and that she knowingly placed or knowingly allowed her children to remain in conditions or surroundings that endangered their physical or emotional well-being.

Section 161.001(b)(1)(D) and (E) allow termination when a parent knowingly exposes a child to dangerous living conditions or places the child with someone whose conduct endangers the child.

In the Interest of L.M.R., C.N.H., C.J.H., and C.O.H., Children v. the State of Texas · filed 2025-08-29(b)(1)(D), (E)

Appellant not only endangered her children by placing them in Larkin’s care—the evidence demonstrates that she knowingly exposed the children to unsafe and inappropriate living conditions that endangered their physical and emotional well-being.

Section 161.001(b)(1)(E) provides an endangerment ground based on a parent’s course of conduct, including conduct during pregnancy, that jeopardizes a child’s physical or emotional well-being.

In the Interest of D. L. a Child v. the State of Texas · filed 2025-08-29(b)(1)(E)

Viewing all the evidence in the light most favorable to jury’s findings, and considering undisputed contrary evidence, there was legally sufficient evidence for the jury to form a firm belief or conviction that Mother violated section 161.001(b)(1)(E).

Section 161.001(b)(1)(E) permits termination for a parent’s endangering course of conduct, while subsection (D) requires evidence of endangering conditions or surroundings.

In the Interest of S.P.A.T., a Child v. the State of Texas · filed 2025-09-10(b)(1)(D), (E)

Here, the evidence supports the trial court’s termination of Father’s parental rights under statutory ground (E) but does not support termination under statutory ground (D).

Subsections (b)(1)(D) and (E) permit termination for knowingly placing a child in endangering surroundings or engaging in an endangering course of conduct, respectively, when clear and convincing evidence also shows termination is in the child’s best interest.

In the Interest of J.M. a Child v. the State of Texas · filed 2025-09-11(b)(1)(D), (E)

And considering the entire record, including evidence both supporting and contradicting the finding, a factfinder reasonably could have formed a firm belief or conviction that Father engaged in a course of conduct that endangered Joseph’s physical and emotional well-being. See id. § 161.001(b)(1)D, (E). Thus, we hold that the evidence is legally and factually sufficient to support the trial court’s predicate findings supporting termination of Father’s parental rights.

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 N.L.S., E.J.C., AKA E.J.C., Children v. Department of Family and Protective Services · filed 2025-10-28(b)(1)(E)

We therefore hold that factually sufficient evidence supports the trial court’s endangerment finding under Section 161.001(b)(1)(E).

Subsection (b)(1)(E) permits termination when clear and convincing evidence shows a course of conduct that endangers a child’s physical or emotional well-being; abuse of other children and domestic violence may support that finding.

In the Interest of B. D. Z.; P. Jr. AKA B. M., a Child v. Department of Family and Protective Services · filed 2025-12-16(b)(1)(E)

This, combined with the evidence of physical abuse of other children and past criminal activity and domestic violence, established clear and convincing proof of a voluntary, deliberate, and conscious course of conduct that endangered Ben’s physical or emotional well-being.

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 J.A.B., S.M.E., C.C.E., and M.B.E., Children v. the State of Texas · filed 2025-12-17(b)(1)(E)

The evidence of repeated domestic violence perpetrated by Father was sufficient to support a firm belief or conviction that Father engaged in a course of conduct that endangered the physical and emotional well-being of the children.

Section 161.001(b)(1)(E) permits termination when a parent’s pattern of conduct endangers a child, even after a brief period of progress.

In the Interest of L.M.J., a Child v. the State of Texas · filed 2025-12-18(b)(1)(E)

The trial court could reasonably conclude that Luke’s brief period of progress, followed by abandonment, presumed positive drug tests, and lack of progress on housing and employment subjected Liam to the same overarching endangering environment that justified termination in R.R.A.

Under subsection (b)(1)(E), repeated criminal conduct and incarceration may establish a course of conduct that endangers a child’s physical or emotional well-being.

In the Interest of E.T., a Child v. the State of Texas · filed 2026-01-22(b)(1)(E)

We thus hold that the evidence is both legally and factually sufficient to support the trial court’s Subsection (E) finding.

Section 161.001(b)(1)(D) and (E) permits termination when clear and convincing evidence establishes endangering conditions or a course of endangering conduct.

In the Interest of Y.B. and N.W., Children v. the State of Texas · filed 2025-10-10(b)(1)(D), (E)

Because we find that legally and factually sufficient evidence supported the trial court’s Ground D and E findings, we overrule Mother’s first point of error.

Section 161.001(b)(1)(D) and (E) provide grounds for termination when a parent knowingly leaves a child in an endangering environment or engages in an endangering course of conduct.

In the Interest of D.M., a Child v. the State of Texas · filed 2025-10-23(b)(1)(D), (E)

Based on the foregoing, we conclude that the evidence is sufficiently clear and convincing such that a reasonable factfinder could have formed a firm conviction or belief that Appellant disregarded her parental obligations to the degree that she knowingly allowed D.M. to remain in an endangering environment and knowingly placed D.M. with persons who engaged in endangering conduct.

Subsection (D) addresses endangerment from a child’s surroundings and environment, while subsection (E) addresses endangerment from parental conduct.

In the Interest of N.L., a Child v. the State of Texas · filed 2025-10-27(b)(1)(D)–(E)

Subsection (D) addresses the child’s surroundings and environment while subsection (E) addresses parental misconduct.

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 repeated illegal drug use can support that finding.

In the Interest of E.N.T. a Child v. Department of Family and Protective Services · filed 2025-11-05(b)(1)(E)

This evidence demonstrates that Mother repeatedly tested positive for multiple illegal drugs while Eva was in the Department’s care, despite knowing that her parental rights were at stake and that she was required to stop using drugs before Eva could be returned to her care, and thus supports the trial court’s endangerment finding under Subsection (E).

Section 161.001(b)(1)(D) permits termination when a parent knowingly places a child in endangering conditions, while subsection (E) permits termination for conduct that endangers a child.

D.T. and M.B.M.V A/K/A M.V, Children v. Department of Family and Protective Services · filed 2025-11-06(b)(1)(D), (E)

We hold that legally and factually sufficient evidence supports the trial court’s findings under subsections (D) and (E).

Subsections (b)(1)(D) and (E) provide grounds for termination based on an endangering environment or endangering conduct, respectively.

In the Interest of F.C. and A.G.C., Children v. the State of Texas · filed 2025-11-20(b)(1)(D), (b)(1)(E)

Considering all the evidence presented in this case in the light most favorable to the trial court’s finding and considering the evidence as a whole, we conclude that the evidence was legally and factually sufficient to support termination of Father’s parental rights under Paragraphs (D) and (E).

Section 161.001(b)(1)(D) and (E) allow termination based on endangering surroundings or a parent's endangering conduct when the required findings are supported by clear and convincing evidence.

In the Interest of G.P.-J.R. and C.S.-L.R., Children v. the State of Texas · filed 2025-12-10(b)(1)(D), (E)

The evidence is legally and factually sufficient to support the trial court’s (D) and (E) finding.

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

In the Interest of A.H. and B.H., Children v. the State of Texas · filed 2025-12-11(b)(1)(E)

Whether we view the record in a light most favorable to the Subsection (E) finding or weigh the disputed evidence for and against the finding, a reasonable factfinder could have formed a firm belief or conviction that Mother had engaged in a course of conduct that had endangered Ann’s and Betty’s physical or emotional well-being.

A parent’s prolonged lack of contact with a child can endanger the child’s emotional well-being under subsection (b)(1)(E).

Bridges v. Ashley Mueller and Jeff Mueller · filed 2025-12-12(b)(1)(E)

And finally, a parent’s significant lack of contact with the child and absence from the child’s life endangers the child’s emotional well-being.

Subsections (b)(1)(D) and (E) permit termination when clear and convincing evidence shows that a parent knowingly exposes children to endangering surroundings or places them with people engaged in endangering conduct.

In the Interest of S.G. and K.C., Children v. the State of Texas · filed 2025-12-18(b)(1)(D), (E)

Based on the foregoing, the evidence is sufficiently clear and convincing such that a reasonable factfinder could have formed a firm conviction or belief that Appellant “knowingly allowed the children to remain in an endangering environment” and “knowingly placed [the children] with persons who engaged in [endangering] conduct.”

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 conduct.

In the Interest of M.M.H.H. AKA M.H., a Child v. Department of Family and Protective Services · filed 2025-12-18(b)(1)(D), (E)

Viewing all the evidence in the light most favorable to the jury’s findings, and considering any undisputed evidence to the contrary, we conclude that a jury reasonably could have formed a firm belief or conviction that Mother engaged in a course of conduct that endangered Molly’s physical and emotional well-being. See TEX. FAM. CODE § 161.001(b)(1)(D), (E).

Section 161.001(b)(1)(D), (E), and (O) provides grounds for termination involving endangering conditions, endangering conduct, or controlled substance use that endangers a child.

In the Interest of J.C. and C.C., Jr., Children v. the State of Texas · filed 2026-01-08(b)(1)(D), (E), and (O)

Considering all the evidence presented in this case in the light most favorable to the trial court's finding and considering the evidence as a whole, we conclude that the evidence was legally and factually sufficient to support termination of the Mother’s parental rights under Paragraphs (D), (E), 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, including criminal conduct that repeatedly leaves the child in unsafe conditions.

E. D. v. Texas Department of Family and Protective Services · filed 2025-12-18(b)(1)(E)

Considered in the light most favorable to the trial court’s finding, the evidence is legally sufficient to support its decision that termination of Father’s parental rights was justified 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; persistent drug use while caring for the child can satisfy that ground.

In the Interest of K.L.B., a Child v. the State of Texas · filed 2025-12-19(b)(1)(E)

This evidence is sufficient to support the factfinder’s conclusion that Mother engaged in a pattern of conduct endangering the child’s physical and emotional well-being.

A pattern of parental conduct exposing a child to a substantial risk of harm from drugs and violence can support an endangerment finding.

In the Interest of N. P. G. a Child v. Department of Family and Protective Services · filed 2026-01-13(b)(1)(E)

The trial court could reasonably have interpreted the above evidence regarding the risk of Mother exposing N.P.G. to drugs and violence as showing a pattern of continued substantial risk of harm to N.P.G. sufficient to support the trial court’s finding of endangerment under subsection (E).

Section 161.001(b)(1)(D) permits termination for endangering conditions or surroundings, while (E) permits termination for endangering conduct; each finding requires clear and convincing evidence.

In the Interest of S.J., a Child v. the State of Texas · filed 2026-01-21(b)(1)(D), (E)

Given scant testimony at trial, we find that it would not be reasonable to form a firm conviction or belief regarding the truth of the Department’s allegations regarding ground D. Accordingly, we reverse the ground D finding. ... After viewing all the evidence in the light most favorable to ground E findings, we conclude that the trial court could have formed a firm belief or conviction that the Department met its burden for terminating Mother’s parental rights under statutory ground E.

Section 161.001(b)(1)(D) and (E) support termination for endangerment when a parent’s pattern of drug use and related dangers present a substantial risk of harm to the child.

In the Interest of P.M.P., a Child v. the State of Texas · filed 2026-01-22(b)(1)(D), (E)

The record as a whole demonstrates that Appellant’s pattern of drug use, accompanied by related dangers to the child, presented a substantial risk of harm to the child and rendered Appellant incapable of parenting.

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.H., a Child v. the State of Texas · filed 2026-01-30(b)(1)(E)

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

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 F.H. and D.K.A., Children v. Department of Family and Protective Services · filed 2026-03-12(b)(1)(E)

The trial court found by clear and convincing evidence that Mother engaged in conduct or knowingly placed the children with persons who engaged in conduct which endangers the children’s physical or emotional well-being. See TEX. FAM. CODE § 161.001(b)(1)(E). ... We therefore conclude that factually sufficient evidence supports the trial court’s finding under subsection (E).

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

In the Interest of K.A.E.E. and K.M.-A.E., Children v. the State of Texas · filed 2026-03-19(b)(1)(E)

Considering all the evidence presented in this case in the light most favorable to the trial court’s finding and considering the evidence as a whole, we conclude that the evidence was legally and factually sufficient to establish that Mother engaged in conduct that endangered the physical or emotional well-being of the children. See TEX. FAM. CODE ANN. § 161.001(b)(1)(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 K. K. E., Child v. Department of Family and Protective Services · filed 2026-03-20(b)(1)(E)

Considering all the evidence, including the disputed evidence that a reasonable factfinder could not have credited in favor of its termination finding under Subsection (E), we conclude that the trial court reasonably could have formed a firm belief or conviction that Mother engaged in a course of endangering conduct. We hold that legally and factually sufficient evidence supports the trial court’s endangerment finding under Subsection (E).

Repeated criminal conduct that causes prolonged parental absence can support an endangerment finding when it puts a child’s physical or emotional well-being at risk.

In the Interest of A.M., a Child v. the State of Texas · filed 2026-04-30(b)(1)(E)

Given Father’s pervasive criminal history, which repeatedly caused his absence from A.M.’s life, a reasonable fact‑finder could form a firm belief or conviction that Father engaged in a course of conduct that endangered A.M.’s physical or emotional well‑being.

Subsection (b)(1)(E) permits termination for a course of conduct endangering a child, including conduct before or after removal, without proof of physical injury to the child.

In the Interest of A.C. and N.C., Children v. the State of Texas · filed 2026-04-30(b)(1)(E)

Both contentions suggest a temporal limitation on the endangerment inquiry that the statute does not support. ... The evidence is legally and factually sufficient to support termination under Subsection (E).

A parent’s own course of endangering conduct can support termination under subsection (b)(1)(E) even if the parent did not know of his paternity.

In the Interest of J.S.C. and J.M.C., Children v. the State of Texas · filed 2026-05-21(b)(1)(E)

However, knowledge of paternity is not a prerequisite to a showing of a parent’s own course of conduct which endangers a child under Subsection (E).

A parent’s heavy marijuana use and neglect of a child’s needs can support a finding of an endangering course of conduct under subsection (E).

In the Interest of P.M.B., J.Q.B., M.B. AKA Baby Girl B., K.L.B. AKA K.L.B., Children v. Department of Family and Protec · filed 2026-05-28(b)(1)(E)

The evidence of Mother’s heavy marijuana use, the events that led to Katie’s hospitalization, and Katie’s diagnosis and treatment is legally and factually sufficient to support the finding that Mother engaged in a course of conduct that endangered Katie’s physical and 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.

In the Interest of B.A. and B.A., Children v. the State of Texas · filed 2026-06-04(b)(1)(E)

Considering the entire record, we conclude that the trial court could have reasonably formed a firm conviction or belief that the Department had proved at least the termination ground in Subsection (E).

Section 161.001(b)(1)(E) permits a conduct-based endangerment finding when a parent repeatedly exposes children to violent relationships, even if the parent is a victim of the violence.

In the Interest of A.M., J.M., and K.W., Children v. the State of Texas · filed 2026-06-04(b)(1)(E)

In other words, the evidence was legally and factually sufficient to support the trial court’s predicate finding of conduct-based endangerment.

Section 161.001(1)(E) permits termination for parental conduct that endangers a child without proof that the conduct caused actual harm to the child.

Matter of WAB · filed 1998-10-29(1)(E)

Therefore, we agree with Delvecceo that the supreme court interprets section 161.001(1)(E) to not require a causal connection between the parent's misconduct and any actual harm to the child resulting from that misconduct.

A parent's repeated failure to protect children from abuse can support a finding that termination is in the children's best interest.

Aguirre v. Texas Department of Protective and Regulatory Services · filed 1996-11-20(2)

There is more than sufficient evidence of specific acts of abuse against these children by their stepfather and the repeated failure of their mother to protect them from this abuse, and specific testimony of her inability to protect them from future abuse, to support the jury's decision that it was in the best interest of the children to terminate Juanita Aguirre's parental rights to her two younger children.

Section 161.001 requires clear and convincing evidence that termination is in the child’s best interest; a jury’s refusal to find that requirement must stand unless the evidence compels the finding.

In the Interest of D.G. · filed 1999-09-01(2)

After reviewing all of the evidence presented and mindful of the fact that we may not reweigh that evidence or reassess the credibility of the witnesses, we cannot conclude that a rational jury could have found only that is was highly probable that termination was in the best interest of the children.

Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of K.C.M. · filed 1999-10-07(2)

Second, termination of parental rights must be in the child’s best interest. ... We conclude that the trial court’s finding, that the “clear and convincing evidence” showed that termination was in the best interest of the child, is against the great weight and preponderance of the evidence and is clearly unjust.

Section 161.001(2) requires clear and convincing evidence that termination is in the child's best interest, and that finding is subject to factual sufficiency review.

In Re KCM · filed 1999-11-04(2)

Second, termination of parental rights must be in the child's best interest. TEX. FAM.CODE ANN. § 161.001(2); Richardson, 677 S.W.2d at 499. ... We conclude that the trial court's finding, that the "clear and convincing evidence" showed that termination was in the best interest of the child, is against the great weight and preponderance of the evidence and is clearly unjust.

Section 161.001(2) does not permit termination of parental rights merely because a child might be better off living elsewhere.

In Re CH · filed 2000-04-20(2)

The best interest standard does not permit parental termination merely because a child might be better off living elsewhere.

Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of C.H. · filed 2000-04-20(2)

In sum, the record before us does not contain clear and convincing evidence that termination of the parent-child relationship is in C.H.’s interest. The record does not adequately support the conclusion that it is highly probable that termination of Ms. Hylton’s parental rights was in the best interest of C.H.

Section 161.001 requires clear and convincing evidence of both a statutory ground for termination and that termination is in the child’s best interest.

In Re KR · filed 2000-07-20(2)

To terminate a natural parent's parental rights, the court must be convinced by clear and convincing evidence that both (1) a statutory ground for termination exists and (2) termination is in the best interest of the child. See TEX. FAM.CODE ANN. § 161.001 (Vernon 1996). ... In light of the facts presented here, we find the evidence is legally and factually sufficient under either the traditional or heightened standards of review.

Section 161.001(2) requires a finding that termination is in the child's best interest after sufficient parental conduct is established.

Bates v. Texas Department of Protective and Regulatory Services · filed 2000-07-27(2)

Once the trial court finds parental conduct sufficient to warrant termination, the trial court must then determine if termination is in the best interest of the child. See Tex. Fam. Code Ann. § 161.001(2) (West Supp. 2000). ... Having reviewed all the evidence, we conclude that the evidence is factually sufficient to support the trial court's finding that termination of Bates' parental rights is in L.B.'s best interest.

Section 161.001 requires a finding of at least one listed parental act or omission and a separate finding that termination is in the child's best interest.

In Re RC · filed 2000-09-28(1), (2)

In addition to finding that one or more of the acts or omissions enumerated under section 161.001(1) occurred, a verdict of termination also requires a finding that termination is in the best interest of the child.

Section 161.001 requires a finding by clear and convincing evidence that termination is in the child’s best interest.

in the Interest of M.A.W. and M.A.W., Children · filed 2000-10-05(2)

We hold that this language complies with the requirements of section 161.001 and constitutes a finding that termination of appellant’s parental rights was in the best interest of the children.

Section 161.001 requires a finding that termination is in the child's best interest for each parent; a jury charge that permits termination without that finding is erroneous.

In Re JFC · filed 2001-07-13(2)

By any reasonable reading, the charge does not require the jury to find that the termination of Tawnya's rights was in the best interest of the children. Nor does it require that the termination of Paige's rights be in the best interest of the children except as to ground "B." This constitutes an obvious and fundamental charge error. The charge fails to require all the findings that, under the Family Code, are necessary to terminate parental rights.

Section 161.001 requires clear and convincing evidence that termination is in the child's best interest, in addition to a statutory ground for termination.

in the Interest of J. H. and A. H., Minor Children · filed 2002-01-24(2)

In order to terminate Herrera's parental rights, Esquivel was required to establish by clear and convincing evidence (1) one of the statutory grounds for termination and (2) that termination is in the children's best interest.

Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

Swate v. Swate · filed 2002-03-06(2)

Additionally, upon review of all the evidence, we hold that the finding is supported by clear and convincing evidence.

Termination requires a finding that it is in the children's best interest, supported here by evidence of unsafe housing and Perez's failure to establish a stable home.

Perez v. Texas Department of Protective and Regulatory Services · filed 2002-04-11(2)

Viewing all the evidence neutrally, we hold that there is factually sufficient evidence to support the finding that termination of Perez's parental rights is in the children's best interest.

Section 161.001(2) requires clear and convincing evidence that termination is in the child's best interest; evidence of a parent's misconduct alone does not establish that requirement.

Horvatich v. TX DEPT. OF PROT. & REG. SER. · filed 2002-05-16(2)

Under the Family Code, a trial court may only order termination of parental rights if, based on clear and convincing evidence, termination is in the best interest of the children. The record in this case, however, does not contain evidence that would even meet the lesser standard of preponderance of the evidence in favor of a finding that termination is in the children's best interest.

Section 161.001(2) requires clear and convincing evidence that termination is in the child's best interest.

Horvatich v. Texas Department of Protective and Regulatory Services · filed 2002-05-16(2)

Therefore, the evidence is factually insufficient to establish by clear and convincing evidence that termination is in the best interest of these three siblings.

Section 161.001(2) requires proof that termination is in the child's best interest.

in the Interest of D. R. P. and T. W. P., Children · filed 2002-06-12(2)

Considering the record as a whole, we conclude the evidence which supports the jury finding is not so weak as to be clearly wrong and manifestly unjust, and is sufficient to support a finding that termination of the parent-child relationship between Parson and her children, D.P. and T.P., is in the best interest of the children.

Section 161.001(2) requires a finding that termination is in the children's best interest; testimony about their basic needs and risk of further abuse can support that finding.

In Re KC · filed 2002-07-10(2)

She argues only that the evidence is factually insufficient to support the trial court's finding that termination is in the children's best interest. See id. at § 161.001(2). We disagree. The trial court's best interest finding is amply supported by the testimony of the Department's supervisor, caseworkers, and mental health specialist, as well as the CASA volunteer appointed to the case, that termination is in the children's best interest so that their basic needs are met and further abuse is avoided.

Section 161.001(2) requires a finding that termination is in the children's best interest; evidence concerning their basic needs and risk of further abuse can support that finding.

in the Interest of K.C., Children · filed 2002-07-10(2)

The trial court's best interest finding is amply supported by the testimony of the Department's supervisor, caseworkers, and mental health specialist, as well as the CASA volunteer appointed to the case, that termination is in the children's best interest so that their basic needs are met and further abuse is avoided.

Section 161.001(2) requires a finding that termination is in the child's best interest; evidence of abuse, an unstable home, and inability to provide for the children supported that finding here.

in the Interest of C.B., V.B. · filed 2002-07-25(2)

Second, termination of parental rights must be in the child's best interest. Tex. Fam. Code Ann. § 161.001(2); K.C.M. , 4 S.W.3d at 394. ... Considering only the evidence and inferences tending to support the trial court's fact findings, and disregarding all contrary evidence and inferences, we conclude that the evidence was legally sufficient to support the trial court's finding that the termination of Leija's parental rights was in the best interest of C.B. and V.B.

Section 161.001(2) requires clear and convincing evidence that termination is in the child's best interest.

In Re CDB · filed 2002-12-05(2)

Under that section, a court may order termination of the parent-child relationship if it finds by clear and convincing evidence one or more of the statutory ground set out in section 161.001(1), and determines that termination is in the best interest of the child as required by section 161.001(2). ... We believe the evidence is legally sufficient because, considering the evidence that supports the finding, the factfinder could reasonably have formed a firm conviction or belief that terminating appellant's rights was in C.D.B.'s best interest.

Section 161.001(2) requires clear and convincing evidence that termination is in the child’s best interest.

In the Interest of C.D.B., a Child · filed 2002-12-05(2)

Under that section, a court may order termination of the parent-child relationship if it finds by clear and convincing evidence one or more of the statutory ground set out in section 161.001(1), and determines that termination is in the best interest of the child as required by section 161.001(2).

Section 161.001 requires proof of a statutory ground and that termination is in the child’s best interest.

in the Interest of W.C., K.A.C., L.C.D., D.J.D., and S.T.D. · filed 2003-02-06(2)

Because we conclude the evidence is factually insufficient to support the jury’s best interest finding, we reverse the trial court’s judgment and remand this cause to the trial court for a new trial. ... In proceedings to terminate the parent-child relationship brought under section 161.001 of the family code, the petitioner must establish one or more of the acts or omissions enumerated under subsection (1) of the statute and, must also prove that termination is in the best interest of the child.

Section 161.001 requires proof of at least one listed parental act or omission and that termination is in the child's best interest.

in the Interest of J.D. · filed 2003-02-13

In proceedings to terminate the parent-child relationship brought under section 161.001 of the family code, the petitioner must establish one or more of the acts or omissions enumerated under subdivision (1) of the statute and must also prove that termination is in the best interest of the child.

Section 161.001(2) requires clear and convincing evidence that termination is in the child's best interest; continued drug use and infrequent visits can support that finding despite a parent's recent treatment efforts.

In Re LM · filed 2003-03-13(2)

We find that the evidence presented was sufficient for a factfinder to reasonably form a firm belief or conviction that termination of the parent-child relationship was in L.M.'s best interests.

Section 161.001 requires termination to be in the child’s best interest, supported by clear and convincing evidence.

In Re CNS · filed 2003-04-02(2)

There must be a predicate act which violates one of the provisions listed in the Family Code, and termination of the parent-child relationship must be in the best interest of the child. Tex. Fam.Code Ann. §§ 161.001, 161.206(a) (Vernon 2002). The petitioner must justify termination by clear and convincing evidence of each of the two prongs. ... Based on all the evidence, including the disputed evidence, we find that a reasonable judge could have formed a firm belief or conviction that terminating John's parental rights was in C.N.'s best interest.

Section 161.001(2) requires clear and convincing evidence that termination is in the child's best interest.

in the Interest of J. R. W., a Child · filed 2003-04-02(2)

Based upon our review of the record, we conclude that the trial court did not err in finding that terminating Alvin's parental rights was in the best interest of J.R.W.

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

In the Interest of C.N.S. · filed 2003-04-02(2)

There must be a predicate act which violates one of the provisions listed in the Family Code, and termination of the parent-child relationship must be in the best interest of the child. Tex. Fam.Code Ann. §§ 161.001, 161.206(a) (Vernon 2002). The petitioner must justify termination by clear and convincing evidence of each of the two prongs. ... Based on all the evidence, including the disputed evidence, we find that a reasonable judge could have formed a firm belief or conviction that terminating John’s parental rights was in C.N.’s best interest.

Section 161.001 requires clear and convincing evidence that termination is in the child's best interest.

Loper v. Texas Department of Protective and Regulatory Services and C. L. · filed 2003-04-03

Having reviewed all the evidence, we hold there was clear-and-convincing evidence supporting the district court's finding that it was in C.L.'s best interest to terminate Loper's parental rights.

Section 161.001 requires proof of a listed ground for termination and that termination is in the child's best interest.

In Re EDL · filed 2003-04-10(2)

In proceedings to terminate the parent-child relationship brought under section 161.001 of the family code, the petitioner must establish one or more of the acts or omissions enumerated under subdivision (1) of the statute and must also prove that termination is in the best interest of the child. ... We have reviewed the record extensively, and under the applicable standards of review, we hold that the evidence was both legally and factually sufficient to constitute clear and convincing evidence to support the trial court's finding that termination was in E.D.L.'s best interest.

Section 161.001 requires proof that termination is in the child’s best interest in addition to a listed ground for termination.

in the Interest of E.D.L., a Child · filed 2003-04-10(2)

In proceedings to terminate the parent-child relationship brought under section 161.001 of the family code, the petitioner must establish one or more of the acts or omissions enumerated under subdivision (1) of the statute and must also prove that termination is in the best interest of the child. ... We have reviewed the record extensively, and under the applicable standards of review, we hold that the evidence was both legally and factually sufficient to constitute clear and convincing evidence to support the trial court’s finding that termination was in E.D.L.’s best interest.

Section 161.001 requires a statutory ground and a finding that termination is in the child's best interest; when the State appeals a failure to find best interest, it must show that termination was the only reasonable decision.

In Re JRK · filed 2003-05-07(2)

Stated another way, the State must show on appeal that the only reasonable decision a factfinder could reach is that termination is in the child's best interest.