Courts consider the Holley factors when reviewing a best interest finding in a child custody or termination proceeding.
A parent challenged the termination of her parental rights, arguing that the child was removed due to the risk of abuse toward a sibling rather than actual abuse or neglect of the child in question. The court must determine if the statutory requirement for removal due to 'abuse or neglect' includes the risks or threats of the environment in which the child is placed. The court holds that the term 'abuse or neglect' includes placing a child at substantial risk of harm, which encompasses the danger faced by other children in the parent's care. Because the parent failed to comply with court-ordered service plans and the child was removed due to these environmental risks, the termination was proper.
At page 249 Establishing removal for neglect under family code provisions353 citing casesstating that in reviewing a best interest finding, “we consider, among other evidence, the Holley factors
- In the Interest of K.J., a Child v. the State of Texas, No. 02-25-00093-CV (Tex. App.—Fort Worth June 5, 2025).published (Many of the reasons 19 supporting termination under [S]ubsection O also support the trial court’s best- interest finding.)
- in the Interest of E.L.H., M.L.H., J.O., & I.L.H., Child., No. 13-22-00192-CV (Tex. App.—Corpus Christi–Edinburg Aug. 25, 2022).published(Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.)
- in the Interest of J.E.M.M & L.A.M.M, Child., 532 S.W.3d 874 (Tex. App.—Houston [14th Dist.] 2017).published(Many of the reasons supporting termination under subsection 0 also support the trial court’s best interest finding.)
- in the Interest of S.D.& G.D., Minor Child., No. 02-16-00280-CV (Tex. App.—Fort Worth Jan. 5, 2017).unpublished (Many of the reasons supporting termination under [subsection 161.001(b)(1)] also support the trial court’s best-interest finding.)
- in the Interest of M.J.W., a Child, No. 14-16-00276-CV, 2016 WL 4206046 (Tex. App.—Houston [14th Dist.] Aug. 9, 2016).published (Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.)
- in the Interest of M.S., a Child, No. 01-15-00451-CV (Tex. App.—Houston [1st Dist.] Sept. 29, 2015).published (Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.)
- in the Interest of T.G., L.G., & M.G., Child., No. 02-15-00147-CV (Tex. App.—Fort Worth July 17, 2015).published (Many of the reasons supporting termination under [section 161.001(b)(1)] also support the trial court’s best- interest finding.)
- in the Interest of L.E.R., a Child, No. 14-15-00205-CV, 2015 WL 3918062 (Tex. App.—Houston [14th Dist.] June 25, 2015).published(Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.)
- in the Interest of J.J.G & D.J.T-B., Child., No. 14-15-00094-CV, 2015 WL 3524371 (Tex. App.—Houston [14th Dist.] June 4, 2015).published(Many of the reasons supporting 12 termination under subsection O also support the trial court’s best interest finding.)
- in the Interest of K.M.-J. AKA K.M-J & D.A.R.-J. v. Dep't of Fam. & Prot. Servs., No. 01-15-00253-CV (Tex. App.—Houston [1st Dist.] June 2, 2015).published (many of the factors supporting termination under subsection O also support the trial court’s best interest finding.)
Show 204 more citing cases
- in the Interest of M.L.G.J., T.M.J., T.L.W.Jr., M.A.J., T.P.R.J., B.W.D. III, M.R.J., L.C.J., Child., No. 14-14-00800-CV, 2015 WL 1402652 (Tex. App.—Houston [14th Dist.] Mar. 24, 2015).published (Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.)
- in the Interest of T.R.M. AKA E. T.M., T.J.W AKA T.W., Child., No. 14-14-00773-CV (Tex. App.—Houston [14th Dist.] Mar. 10, 2015).published (Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.)
- in the Interest of B.G. AKA I.G., a Child, No. 14-14-00729-CV (Tex. App.—Houston [14th Dist.] Feb. 2, 2015).published (Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.)
- in the Interest of I.R., a Minor Child, No. 14-14-00626-CV (Tex. App.—Houston [14th Dist.] Dec. 9, 2014).published (Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.)
- in the Interest of C.N.S, & C.D.S., Child., No. 14-14-00301-CV, 2014 WL 3887722 (Tex. App.—Houston [14th Dist.] Aug. 7, 2014).published (Many of the reasons supporting termination under subsection O also support the trial court’s best interest 14 finding.)
- in the Interest of A.R.B., C.L.B., C.L.B. Jr., & E.B., Child., No. 14-14-00146-CV (Tex. App.—Houston [14th Dist.] June 26, 2014).published (Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.)
- S.L. v. Dep't of Fam. & Prot. Servs., No. 14-22-00194-CV, 2022 WL 4103250 (Tex. App.—Houston [14th Dist.] Sept. 8, 2022).published([m]any of the reasons supporting termination under subsection O also support the trial court’s best interest finding)
- in the Interest of R.N.Y., a Child, No. 14-14-00984-CV (Tex. App.—Houston [14th Dist.] Apr. 28, 2015).published(Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.)
- In the Interest of L.Q.-W., L.W., & L.W., Child. v. the State of Texas, No. 02-26-00228-CV (Tex. App.—Fort Worth Aug. 13, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of G.H., a Child v. the State of Texas, No. 11-26-00012-CV, 2026 WL 1992098 (Tex. App.—Eastland July 10, 2026).published See In re H.S., No. 24-0307, 2026 WL 1614496 , at *9 (Tex. June 5, 2026) (Although heightened appellate review applies to both subsections, evidence that supports a finding under 9 subsection (b)(1) “may also be, and indeed often is, relev…
- In the Interest of B.A. & B.A., Child. v. the State of Texas, No. 02-26-00055-CV (Tex. App.—Fort Worth June 4, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of D.J., a Child v. the State of Texas, No. 02-26-00022-CV (Tex. App.—Fort Worth Apr. 30, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of B.G.T. AKA E.T., a Child v. the State of Texas, No. 06-25-00113-CV (Tex. App.—Texarkana Apr. 21, 2026).publishedIn re E.C.R., 402 S.W.3d 239, 249 (Tex. 2013).
- In the Interest of A.S., a Child v. the State of Texas, No. 02-25-00645-CV (Tex. App.—Fort Worth Apr. 16, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of J.D., R.D.-G., K.G., & L.G., Child. v. the State of Texas, No. 02-25-00574-CV (Tex. App.—Fort Worth Mar. 26, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of J.P. & I.P., Child. v. the State of Texas, No. 02-25-00437-CV (Tex. App.—Fort Worth Feb. 12, 2026).published In re E.C.R., 402 S.W.3d 239, 249 (Tex. 2013); C.H., 89 S.W.3d at 28 ; see Tex. Fam.
- In the Interest of I.H., a Child v. the State of Texas, No. 02-25-00524-CV (Tex. App.—Fort Worth Jan. 30, 2026).published In re E.C.R., 402 S.W.3d 239, 249 (Tex. 2013); In re C.H., 89 S.W.3d 17, 28 (Tex. 2002); In re B.H.R., 535 S.W.3d 114, 123 (Tex. App.—Texarkana 2017, no pet.).
- In the Interest of E.T., a Child v. the State of Texas, No. 02-25-00545-CV (Tex. App.—Fort Worth Jan. 22, 2026).published In re E.C.R., 402 S.W.3d 239, 249 (Tex. 2013); C.H., 89 S.W.3d at 28 ; see Tex. Fam.
- In the Interest of T.D.-B., a Child v. the State of Texas, No. 06-25-00054-CV (Tex. App.—Texarkana Dec. 19, 2025).published Rather, “endanger” means to expose to loss or injury; to jeopardize. 18 There is a Texas Supreme Court decision that has a lone mention of “substantial risk of continuing danger.” In re E.C.R., 402 S.W.3d 239, 249 (Tex. 2013).
- In the Interest of T.D.-B., a Child v. the State of Texas, No. 06-25-00054-CV (Tex. App.—Texarkana Dec. 12, 2025).published Rather, “endanger” means to expose to loss or injury; to jeopardize. 17 There is a Texas Supreme Court decision that has a lone mention of “substantial risk of continuing danger.” In re E.C.R., 402 S.W.3d 239, 249 (Tex. 2013).
- In the Interest of M.B.-O., B.B.-O., D.B.-O., & J.B.-O., Child. v. the State of Texas, No. 02-25-00306-CV (Tex. App.—Fort Worth Dec. 11, 2025).published In re E.C.R., 402 S.W.3d 239, 249 (Tex. 2013); C.H., 89 S.W.3d at 28 ; see Tex. Fam.
- In the Interest of N.L., a Child v. the State of Texas, No. 02-25-00205-CV, 2025 WL 3008022 (Tex. App.—Fort Worth Oct. 27, 2025).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of L.C., a Child v. the State of Texas, No. 02-24-00510-CV (Tex. App.—Fort Worth June 26, 2025).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of D.S., D.S., D.S., & D.B., Child. v. the State of Texas, No. 02-25-00124-CV (Tex. App.—Fort Worth June 19, 2025).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of B.C., a Child v. the State of Texas, No. 02-24-00541-CV (Tex. App.—Fort Worth May 22, 2025).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of C.E., a Child v. the State of Texas, No. 02-22-00285-CV (Tex. App.—Fort Worth Apr. 24, 2025).published In re E.C.R., 402 S.W.3d 239, 249 (Tex. 2013); C.H., 89 S.W.3d at 28 ; see Tex. Fam.
- In the Interest of E.C., a Child v. the State of Texas, No. 05-23-00586-CV (Tex. App.—Dallas Dec. 19, 2023).published
- in the Interest of A.H., No. 09-19-00025-CV (Tex. App.—Beaumont May 23, 2019).published
- In the Interest of A.B., a Child v. the State of Texas, No. 11-24-00206-CV (Tex. App.—Eastland Feb. 6, 2025).published
- in the Interest of F.J., a Child, No. 06-18-00111-CV (Tex. App.—Texarkana Mar. 19, 2019).published
- in the Interest of W.D & C.D., Child., No. 10-18-00339-CV (Tex. App.—Waco Mar. 20, 2019).published
- in the Interest of R.M.C., a Child, No. 04-18-00706-CV (Tex. App.—San Antonio Mar. 27, 2019).published
- in the Interest of S.B., T.B., A.B., & K.B., Child., No. 02-18-00310-CV (Tex. App.—Fort Worth Mar. 28, 2019).published
- in the Interest of D.D.-G.P., a Child, No. 01-18-00728-CV (Tex. App.—Houston [1st Dist.] Apr. 2, 2019).published
- in the Interest of K.M.J., a Child, No. 04-18-00727-CV, 2019 WL 1459565 (Tex. App.—San Antonio Apr. 3, 2019).published
- in the Interest of C.A.G. III, a Child, No. 14-18-00930-CV (Tex. App.—Houston [14th Dist.] Apr. 9, 2019).published
- in the Interest of M.M., a Child, No. 02-18-00337-CV (Tex. App.—Fort Worth Apr. 11, 2019).published
- in the Interest of Z.S., Child, No. 02-18-00335-CV (Tex. App.—Fort Worth Apr. 18, 2019).published
- in the Interest of S.S., a Child, No. 02-18-00353-CV (Tex. App.—Fort Worth Apr. 18, 2019).published
- in the Interest of J.J.L., a Child v. Texas Dep't of Fam. & Prot. Servs., 578 S.W.3d 601 (Tex. App.—Houston [14th Dist.] 2019).published
- in the Interest of J.C.R., a Child, No. 04-18-00949-CV, 2019 WL 2110109 (Tex. App.—San Antonio May 15, 2019).published
- in the Interest of T.R.S., No. 09-18-00482-CV (Tex. App.—Beaumont June 13, 2019).published
- in the Interest of S.C., a Child, No. 02-18-00422-CV (Tex. App.—Fort Worth June 13, 2019).published
- in the Interest of Z.N.J., a Child, No. 07-19-00102-CV (Tex. App.—Amarillo June 28, 2019).published
- in the Interest of A. N., Child., No. 04-19-00037-CV (Tex. App.—San Antonio July 24, 2019).published
- in the Interest of A.M & H.M., Child., No. 02-19-00023-CV (Tex. App.—Fort Worth July 25, 2019).published
- in the Interest of A.B.-G. & A.B.-G., Child., No. 02-19-00066-CV (Tex. App.—Fort Worth Aug. 8, 2019).published
- in the Interest of K.J.G., Jr., No. 04-19-00102-CV, 2019 WL 3937278 (Tex. App.—San Antonio Aug. 21, 2019).published
- in the Interest of K. M., Jr. a Child v. Dep't of Fam. & Prot. Servs., No. 01-19-00285-CV (Tex. App.—Houston [1st Dist.] Aug. 22, 2019).published
- in the Interest of K.A., a Child, No. 02-19-00099-CV, 2019 WL 4309168 (Tex. App.—Fort Worth Sept. 12, 2019).published
- in the Interest of A.E., a Child, No. 02-19-00173-CV (Tex. App.—Fort Worth Oct. 1, 2019).published
- in the Interest of K.B., a Child, No. 05-19-00700-CV (Tex. App.—Dallas Oct. 25, 2019).published
- in the Interest of S.M.P.M. & N.J.M., Jr., Child., No. 04-19-00345-CV (Tex. App.—San Antonio Nov. 13, 2019).published
- in the Interest of K.D. & V.P.D., Child., No. 11-19-00164-CV (Tex. App.—Eastland Nov. 14, 2019).published
- in the Interest of K.H., Q.H., Q.H., & S.R., Child., No. 02-19-00247-CV (Tex. App.—Fort Worth Nov. 22, 2019).published
- in the Interest of T.C., a Child, No. 02-19-00291-CV (Tex. App.—Fort Worth Dec. 5, 2019).published
- in the Interest of M.R., a Child, No. 02-19-00212-CV (Tex. App.—Fort Worth Jan. 14, 2020).published
- in the Interest of R.H. & R.C., Child., No. 02-19-00273-CV (Tex. App.—Fort Worth Dec. 12, 2019).published
- in the Interest of J.P-L., a Child, No. 02-19-00255-CV (Tex. App.—Fort Worth Dec. 19, 2019).published
- in the Interest of L.E., Z.S.A.-F. AKA Z.A., & K.A., Child., No. 07-19-00317-CV (Tex. App.—Amarillo Jan. 3, 2020).published
- in the Interest of K.C., a Child, No. 02-19-00293-CV (Tex. App.—Fort Worth Jan. 23, 2020).published
- in the Interest of S.S., a Child, No. 07-19-00309-CV (Tex. App.—Amarillo Feb. 6, 2020).published
- in the Interest of M.T. & J.T., Child., No. 07-19-00320-CV (Tex. App.—Amarillo Feb. 20, 2020).published
- in the Interest of B.B., a Child, No. 02-19-00250-CV (Tex. App.—Fort Worth Mar. 5, 2020).published
- in the Interest of G.S., a Child, No. 02-19-00390-CV (Tex. App.—Fort Worth Mar. 19, 2020).published
- in the Interest of D.R.C., a Child, No. 07-19-00428-CV, 2020 Tex. App. LEXIS 2524 (Tex. App.—Amarillo Mar. 25, 2020).published
- in the Interest of L.C.L. & M.E.M., Child., 599 S.W.3d 79 (Tex. App.—Houston [14th Dist.] 2020).published
- in the Interest of J v. a Child, No. 02-19-00392-CV (Tex. App.—Fort Worth Apr. 1, 2020).published
- in the Interest of L.N.J., Jr., a Child, No. 07-20-00072-CV (Tex. App.—Amarillo Apr. 30, 2020).published
- in the Interest of E.C., a Child, No. 02-20-00022-CV (Tex. App.—Fort Worth Apr. 30, 2020).published
- in the Interest of A.S. & S.S., Child., No. 02-19-00429-CV, 2020 WL 2071944 (Tex. App.—Fort Worth Apr. 30, 2020).published
- in the Interest of A.R., M.R., K.G.D.R., Child. v. ., No. 04-20-00066-CV (Tex. App.—San Antonio Aug. 24, 2020).published
- in the Interest of M.D., a Child v. Texas Dep't of Fam. & Prot. Servs., No. 14-20-00244-CV (Tex. App.—Houston [14th Dist.] Sept. 21, 2020).published
- in the Interest of H.L., a Child, No. 02-20-00120-CV (Tex. App.—Fort Worth Oct. 8, 2020).published
- in the Interest of M.S. & S.S., Child., No. 02-20-00147-CV (Tex. App.—Fort Worth Oct. 15, 2020).published
- in the Interest of Z.A.R. A/K/A Z.R., a Child v. Texas Dep't of Fam. & Prot. Servs., No. 14-20-00511-CV (Tex. App.—Houston [14th Dist.] Dec. 31, 2020).published
- in the Interest of E.R., P.R., Jr., S.R., & S.R., Child., No. 07-20-00276-CV (Tex. App.—Amarillo Feb. 2, 2021).published
- in the Interest of A.J.F., a Child, No. 07-20-00242-CV (Tex. App.—Amarillo Feb. 4, 2021).published
- in the Interest of L.F., a Child, No. 07-20-00316-CV (Tex. App.—Amarillo Feb. 23, 2021).published
- in the Interest of B.J.B. & J.D.D., Child., No. 07-20-00278-CV (Tex. App.—Amarillo Apr. 9, 2021).published
- in the Interest of T.R., T.R., & R.N.-R., Child., No. 02-20-00359-CV (Tex. App.—Fort Worth Apr. 15, 2021).published
- in the Interest of R.H., F v. M v. & P.H., Child., No. 02-20-00396-CV (Tex. App.—Fort Worth May 20, 2021).published
- in the Interest of J.G., a Child, No. 02-21-00020-CV (Tex. App.—Fort Worth July 15, 2021).published
- in the Interest of W.T., a Child, No. 07-21-00100-CV (Tex. App.—Amarillo July 20, 2021).published
- in the Interest of A.W., a Child, No. 02-21-00058-CV (Tex. App.—Fort Worth July 29, 2021).published
- in the Interest of J.S., G.S., & I.F., Child., No. 07-21-00110-CV (Tex. App.—Amarillo Sept. 17, 2021).published
- in the Interest of A.A., G.A., & K.A., Child., 635 S.W.3d 430 (Tex. App.—Amarillo 2021).published
- in the Interest of M.M. & E.L., Child., No. 02-21-00185-CV (Tex. App.—Fort Worth Nov. 10, 2021).published
- A. W. v. Texas Dep't of Fam. & Prot. Servs., No. 03-21-00324-CV (Tex. App.—Austin Dec. 15, 2021).published
- in the Interest of J.B., a Child, No. 02-21-00239-CV (Tex. App.—Fort Worth Dec. 30, 2021).published
- in the Interest of B.H. A/K/A M.O., a Child, No. 02-21-00233-CV (Tex. App.—Fort Worth Jan. 6, 2022).published
- in the Interest of C.W. & M.W., Child., No. 02-21-00252-CV (Tex. App.—Fort Worth Jan. 13, 2022).published
- in the Interest of A.G., a Child, No. 02-21-00297-CV (Tex. App.—Fort Worth Feb. 17, 2022).published
- in the Interest of J.M. & J.M., Child., No. 02-21-00346-CV (Tex. App.—Fort Worth Mar. 24, 2022).published
- in the Interest of E.M., a Child, No. 02-21-00326-CV (Tex. App.—Fort Worth Mar. 24, 2022).published
- in the Interest of L.A v. & S.H v., No. 14-21-00430-CV (Tex. App.—Houston [14th Dist.] Mar. 31, 2022).published
- in the Interest of L.O., A.O. III, C.O., A.O., N.O., A.O. L.W. & T.J., Child., No. 02-21-00376-CV, 2022 WL 1257384 (Tex. App.—Fort Worth Apr. 28, 2022).published
- in the Interest of I.B., Jr., a Child, No. 02-21-00358-CV, 2022 WL 1257133 (Tex. App.—Fort Worth Apr. 28, 2022).published
- A. F. v. Texas Dep't of Fam. & Prot. Servs., No. 03-21-00670-CV (Tex. App.—Austin June 9, 2022).published
- in the Interest of V.S., a Child, No. 02-22-00063-CV, 2022 WL 2252775 (Tex. App.—Fort Worth June 23, 2022).published
- in the Interest of C.L.-F., a Child, No. 02-22-00021-CV, 2022 WL 2353091 (Tex. App.—Fort Worth June 30, 2022).published
- in the Interest of T.M., a Child, No. 02-22-00070-CV (Tex. App.—Fort Worth July 7, 2022).published
- in the Interest of E.A.D., a Child, No. 14-22-00025-CV, 2022 WL 2663981 (Tex. App.—Houston [14th Dist.] July 11, 2022).published
- in the Interest of M. H., a Child, No. 02-22-00048-CV (Tex. App.—Fort Worth July 21, 2022).published
- in the Interest of S.W., a Child, No. 02-22-00097-CV (Tex. App.—Fort Worth Aug. 25, 2022).published
- in the Interest of N.H., M.H., K.R., B.K., H.K., H.K., & H.T., Child., No. 02-22-00157-CV, 2022 WL 4374638 (Tex. App.—Fort Worth Sept. 22, 2022).published
- in the Interest of A.I., a Child, No. 02-22-00176-CV (Tex. App.—Fort Worth Sept. 22, 2022).published
- in the Interest of G.W., a Child, No. 02-22-00181-CV (Tex. App.—Fort Worth Sept. 29, 2022).published
- in the Interest of T.D., a Child, No. 02-22-00215-CV, 2022 WL 11483054 (Tex. App.—Fort Worth Oct. 20, 2022).published
- in the Interest of C.B., C.B., & K.B., Child., No. 02-22-00212-CV (Tex. App.—Fort Worth Oct. 27, 2022).published
- in the Interest of A.P., B.P., D.P., & A.P., Child., No. 02-22-00180-CV (Tex. App.—Fort Worth Nov. 3, 2022).published
- in the Interest of A v. & L v. Child., No. 07-22-00021-CV (Tex. App.—Amarillo Nov. 16, 2022).published
- in the Interest of H.M.R.J, No. 09-22-00171-CV (Tex. App.—Beaumont Nov. 17, 2022).published
- in the Interest of E.B., a Child, No. 02-22-00205-CV (Tex. App.—Fort Worth Nov. 23, 2022).published
- in the Interest of D.A., D.A., C.A., S.A., & C.A., Child., No. 02-22-00260-CV, 2022 WL 17841133 (Tex. App.—Fort Worth Dec. 22, 2022).published
- in the Interest of P.W. & E.W., Child., No. 10-22-00259-CV (Tex. App.—Waco Jan. 4, 2023).published
- J. M. v. Texas Dep't of Fam. & Prot. Servs., No. 03-22-00435-CV (Tex. App.—Austin Jan. 17, 2023).published
- in the Interest of A.C., D.C., & L.C., Child., No. 02-22-00321-CV (Tex. App.—Fort Worth Jan. 26, 2023).published
- J. C. & A. C. v. Texas Dep't of Fam. & Prot. Servs., No. 03-22-00583-CV (Tex. App.—Austin Feb. 23, 2023).published
- In the Interest of K.A., M.A., & P.G., Child. v. the State of Texas, No. 02-22-00442-CV (Tex. App.—Fort Worth Mar. 9, 2023).published
- In the Interest of A. M. v. Dep't of Fam. & Prot. Servs., No. 01-22-00689-CV (Tex. App.—Houston [1st Dist.] Mar. 14, 2023).published
- In the Interest of L.D.T.P., a Child v. the State of Texas, No. 14-22-00815-CV (Tex. App.—Houston [14th Dist.] Apr. 27, 2023).published
- In the Interest of B. S., Child v. Texas Dep't of Fam. & Prot. Servs., No. 01-22-00826-CV (Tex. App.—Houston [1st Dist.] Apr. 27, 2023).published
- In the Interest of D.W., K.W. & L.W., Child. v. the State of Texas, No. 02-22-00478-CV (Tex. App.—Fort Worth May 11, 2023).published
- In the Interest of Z.G., a Child v. the State of Texas, No. 02-23-00038-CV, 2023 WL 3521848 (Tex. App.—Fort Worth May 18, 2023).published
- In the Interest of G.M. & A.M., Child. v. the State of Texas, No. 02-23-00044-CV (Tex. App.—Fort Worth May 25, 2023).published
- In the Interest of S.C.M., a Child v. Dep't of Fam. & Prot. Servs., No. 01-22-00964-CV, 2023 WL 3873342 (Tex. App.—Houston [1st Dist.] June 8, 2023).published
- In the Interest of M.G., a Child v. the State of Texas, No. 02-23-00074-CV, 2023 WL 4008687 (Tex. App.—Fort Worth June 15, 2023).published
- In the Interest of G.M., a Child v. the State of Texas, No. 02-23-00061-CV (Tex. App.—Fort Worth June 29, 2023).published
- In the Interest of J.S.H.,D.P.C.H., B.I.H., C.C.H., & C.L.H.,II, Child. v. the State of Texas, No. 04-23-00078-CV (Tex. App.—San Antonio July 19, 2023).published
- In the Interest of S.N.B v. the State of Texas, No. 09-23-00065-CV (Tex. App.—Beaumont July 27, 2023).published
- In the Interest of J.E. & A.E., Child. v. the State of Texas, No. 02-23-00141-CV (Tex. App.—Fort Worth Aug. 10, 2023).published
- In the Interest of J.P.H. v. the State of Texas, No. 04-23-00131-CV, 2023 WL 5280376 (Tex. App.—San Antonio Aug. 16, 2023).published
- In the Interest of S.M.M., a Child v. the State of Texas, No. 05-23-00533-CV (Tex. App.—Dallas Sept. 11, 2023).published
- In the Interest of S v. J v. & K v. Child. v. the State of Texas, No. 02-23-00188-CV (Tex. App.—Fort Worth Sept. 14, 2023).published
- In the Interest of D.R., R.R., A.R., & J.R., Child. v. the State of Texas, No. 02-23-00093-CV (Tex. App.—Fort Worth Sept. 14, 2023).published
- In the Interest of C.C., a Child v. the State of Texas, No. 02-23-00128-CV (Tex. App.—Fort Worth Sept. 14, 2023).published
- In the Interest of B.U., a Child v. the State of Texas, No. 02-23-00150-CV, 2023 WL 5967604 (Tex. App.—Fort Worth Sept. 14, 2023).published
- In the Interest of K.J. & C.W., Child. v. the State of Texas, No. 02-23-00198-CV (Tex. App.—Fort Worth Oct. 5, 2023).published
- In the Interest of E.J., B.J., K.C. & K.C., Child. v. the State of Texas, No. 02-23-00113-CV (Tex. App.—Fort Worth Oct. 5, 2023).published
- In the Interest of R.E. & A.E., Child. v. the State of Texas, No. 02-23-00255-CV (Tex. App.—Fort Worth Nov. 16, 2023).published
- In the Interest of M.J.A., J.D.Z., & P.I.Z., Child. v. the State of Texas, No. 04-23-00615-CV (Tex. App.—San Antonio Dec. 20, 2023).published
- In the Interest of P.P.-S., & G.P.-S., Child. v. the State of Texas, No. 02-23-00309-CV, 2024 WL 123654 (Tex. App.—Fort Worth Jan. 11, 2024).published
- In the Interest of B. J. F. v. Dep't of Fam. & Prot. Servs., No. 01-23-00522-CV, 2024 WL 117174 (Tex. App.—Houston [1st Dist.] Jan. 11, 2024).published
- In the Interest of A.H. & K.H., Child. v. the State of Texas, No. 02-23-00348-CV (Tex. App.—Fort Worth Jan. 18, 2024).published
- In the Interest of P.M. & A.M., Child. v. the State of Texas, No. 02-23-00365-CV (Tex. App.—Fort Worth Mar. 7, 2024).published
- In the Interest of R.H., a Child v. the State of Texas, 693 S.W.3d 846 (Tex. App.—Fort Worth 2024).published
- In the Interest of H.S., B.S., & M.S., Child. v. the State of Texas, 710 S.W.3d 248 (Tex. App.—Fort Worth 2024).published
- In the Interest of J.C.D.Y. AKA J.Y., J.E.D.Y. AKA J.Y., M.M.D.Y. AKA M.Y., I.E.J. AKA I.J., M.D.K.G. AKA M.Y. AKA M.O.D.Y., & J.T.D.Y. AKA J.Y., Child. v. Dep't of Fam. & Prot. Servs., No. 01-23-00713-CV, 2024 WL 1334334 (Tex. App.—Houston [1st Dist.] Mar. 29, 2024).published
- In the Interest of O.P.-W. Jr. & A. O. P.-W., Child. v. Dep't of Fam. & Prot. Servs., No. 01-23-00692-CV (Tex. App.—Houston [1st Dist.] Mar. 19, 2024).published
- In the Interest of H.C., a Child v. the State of Texas, No. 02-23-00477-CV, 2024 WL 1561513 (Tex. App.—Fort Worth Apr. 11, 2024).published
- In the Interest of C.N.L. & C.T.F., Child. v. the State of Texas, No. 13-23-00591-CV (Tex. App.—Corpus Christi–Edinburg Apr. 25, 2024).published
- In the Interest of J.E.R.A, J.G.A.B, Child. v. Dep't of Fam. & Prot. Servs., No. 14-23-00851-CV (Tex. App.—Houston [14th Dist.] May 2, 2024).published
- In the Interest of S.O., a Child v. the State of Texas, No. 02-23-00480-CV (Tex. App.—Fort Worth May 9, 2024).published
- In the Interest of A.S., a Child v. the State of Texas, No. 02-24-00072-CV (Tex. App.—Fort Worth May 30, 2024).published
- In the Interest of N.M. & H.M., Child. v. the State of Texas, No. 02-24-00062-CV (Tex. App.—Fort Worth June 13, 2024).published
- In the Interest of J.G., J.G., J.G., & J.Z., Child. v. the State of Texas, No. 02-24-00022-CV (Tex. App.—Fort Worth June 13, 2024).published
- In the Interest of M.G., a Child v. the State of Texas, No. 02-24-00026-CV (Tex. App.—Fort Worth June 27, 2024).published
- In the Interest of B.M.P.J., a Child v. the State of Texas, No. 13-24-00134-CV (Tex. App.—Corpus Christi–Edinburg July 5, 2024).published
- In the Interest of K.W., a Child v. the State of Texas, No. 02-24-00082-CV (Tex. App.—Fort Worth July 18, 2024).published
- In the Interest of E.A.O.E. AKA E.O.E., G.E.O.E. AKA G.O.E., Child. v. the State of Texas, No. 14-24-00240-CV (Tex. App.—Houston [14th Dist.] Aug. 20, 2024).published
- In the Interest of A.M., a Child v. the State of Texas, No. 02-24-00199-CV (Tex. App.—Fort Worth Sept. 12, 2024).published
- In the Interest of P.W., a Child v. the State of Texas, No. 02-24-00211-CV (Tex. App.—Fort Worth Sept. 26, 2024).published
- In the Interest of J.D.R., a Child v. the State of Texas, No. 04-24-00337-CV (Tex. App.—San Antonio Sept. 25, 2024).published
- In the Interest of J.H., A.H., & S.H., Child. v. the State of Texas, No. 02-24-00215-CV (Tex. App.—Fort Worth Oct. 17, 2024).published
- In the Interest of J.A.D., a Child v. the State of Texas, No. 04-24-00292-CV (Tex. App.—San Antonio Oct. 16, 2024).published
- In the Interest of T.E., a Minor Child v. the State of Texas, No. 02-24-00271-CV (Tex. App.—Fort Worth Oct. 31, 2024).published
- In the Interest of K.A., a Child v. the State of Texas, No. 02-24-00323-CV (Tex. App.—Fort Worth Oct. 31, 2024).published
- In the Interest of W.H., V.H., E.H., & C.R., Child. v. the State of Texas, No. 02-24-00291-CV (Tex. App.—Fort Worth Nov. 7, 2024).published
- In the Interest of O.S., a Child v. the State of Texas, No. 02-24-00295-CV (Tex. App.—Fort Worth Nov. 14, 2024).published
- In the Interest of J.G., a Child v. the State of Texas, No. 05-24-00940-CV (Tex. App.—Dallas Nov. 12, 2024).published
- In the Interest of J.D., J.D., E.R., M.R., & G.R., Child. v. the State of Texas, No. 02-24-00404-CV, 2025 WL 52128 (Tex. App.—Fort Worth Jan. 9, 2025).published
- In the Interest of T.E. & M.E., Child. v. the State of Texas, No. 10-24-00278-CV (Tex. App.—Waco Feb. 6, 2025).published
- In the Interest of S.D.G. A/K/A S.D.R.S.G., a Child v. the State of Texas, No. 13-24-00433-CV (Tex. App.—Corpus Christi–Edinburg Feb. 6, 2025).published
- In the Interest of G.J., a Child v. the State of Texas, No. 02-24-00368-CV (Tex. App.—Fort Worth Feb. 6, 2025).published
- In the Interest of K.G.Jr., a Child v. the State of Texas, No. 11-24-00236-CV (Tex. App.—Eastland Feb. 13, 2025).published
- In the Interest of I.A. & A.A., Child. v. the State of Texas, No. 02-24-00471-CV (Tex. App.—Fort Worth Feb. 13, 2025).published
- In the Interest of E.M., I.M., W.M., E.M., M.M., Child. v. the State of Texas, No. 11-24-00248-CV (Tex. App.—Eastland Feb. 27, 2025).published
- In the Interest of B.J., a Child v. the State of Texas, No. 02-24-00428-CV (Tex. App.—Fort Worth Feb. 27, 2025).published
- In the Interest of L.I., a Child v. the State of Texas, No. 02-24-00445-CV (Tex. App.—Fort Worth Mar. 6, 2025).published
- In the Interest of K.H., a Child v. the State of Texas, No. 13-24-00486-CV (Tex. App.—Corpus Christi–Edinburg Mar. 13, 2025).published
- In the Interest of E.J.C.T., a Child v. the State of Texas, No. 04-24-00663-CV (Tex. App.—San Antonio Mar. 19, 2025).published
- In the Interest of M.H., S.H., & B.H., Child. v. the State of Texas, No. 02-24-00487-CV (Tex. App.—Fort Worth Mar. 27, 2025).published
- In the Interest of R.F. Jr., a Child v. the State of Texas, No. 11-24-00271-CV (Tex. App.—Eastland Apr. 3, 2025).published
- In the Interest of A.W., M.B. & J.B., Child. v. the State of Texas, No. 02-24-00544-CV (Tex. App.—Fort Worth Apr. 3, 2025).published
- In the Interest of K.B., a Child v. the State of Texas, No. 10-24-00360-CV (Tex. App.—Waco Apr. 10, 2025).published
- In the Interest of E.A., C.A., L.A., & E.A., Child. v. the State of Texas, No. 02-24-00535-CV (Tex. App.—Fort Worth Apr. 10, 2025).published
- In the Interest of A.C.P., A.I.P., A.M.P., M.J-R.P. III, & M.C.S., Child. v. the State of Texas, No. 04-24-00653-CV (Tex. App.—San Antonio June 25, 2025).published
- In the Interest of A.L.W., a Child v. the State of Texas, No. 04-24-00874-CV (Tex. App.—San Antonio July 30, 2025).published
- In the Interest of L.M.R., C.N.H., C.J.H., & C.O.H., Child. v. the State of Texas, No. 11-25-00055-CV (Tex. App.—Eastland Aug. 29, 2025).published
- In the Interest of Z.B.; Child v. Dep't of Fam. & Prot. Servs., No. 01-25-00273-CV (Tex. App.—Houston [1st Dist.] Oct. 7, 2025).published
- In the Interest of D.M., a Child v. the State of Texas, No. 11-25-00102-CV (Tex. App.—Eastland Oct. 23, 2025).published
- In the Interest of J.S., a Child v. the State of Texas, No. 11-25-00079-CV (Tex. App.—Eastland Nov. 6, 2025).published
- In the Interest of S.G. & K.C., Child. v. the State of Texas, No. 11-25-00176-CV (Tex. App.—Eastland Dec. 18, 2025).published
- In the Interest of T.B., K.B., T.B., K.B., Child. v. the State of Texas, No. 11-25-00248-CV (Tex. App.—Eastland Feb. 12, 2026).published
- In the Interest of K.H., K.A., K.A., Child. v. the State of Texas, No. 11-25-00255-CV (Tex. App.—Eastland Feb. 27, 2026).published
- In the Interest of C.R., a Child v. the State of Texas, No. 04-25-00613-CV (Tex. App.—San Antonio Feb. 25, 2026).unpublished
- In the Interest of R.H. & E.H., Child. v. the State of Texas, No. 11-25-00317-CV (Tex. App.—Eastland Apr. 16, 2026).published
- In the Interest of E.T., E.T., E.T., E.D., Child. v. the State of Texas, No. 11-25-00318-CV (Tex. App.—Eastland Apr. 30, 2026).published
- In the Interest of C.F., a Child v. the State of Texas, No. 11-25-00321-CV (Tex. App.—Eastland Apr. 30, 2026).published
- In the Interest of G.S.S. & S.D.S., Child. v. the State of Texas, No. 11-25-00352-CV (Tex. App.—Eastland May 14, 2026).published
- In the Interest of D.W., A.W., B.S.D, & T.G., Child. v. the State of Texas, No. 11-25-00357-CV (Tex. App.—Eastland May 21, 2026).published
- In the Interest of A.D., S.R., & K.A., Child. v. the State of Texas, No. 11-25-00383-CV (Tex. App.—Eastland June 18, 2026).published
- M. P. v. Texas Dep't of Fam. & Prot. Servs., No. 03-22-00163-CV (Tex. App.—Austin Sept. 16, 2022).published
At page 250 Examining entire record for child's best interest229 citing casesconsidering removal of four other children in best interest determination
- in the Interest of S.D.& G.D., Minor Child., No. 02-16-00280-CV (Tex. App.—Fort Worth Jan. 5, 2017).unpublished See E.C.R., 402 S.W.3d at 249 (“Many of the reasons supporting termination under [subsection 161.001(b)(1)] also support the trial court’s best-interest finding.”).
- in the Interest of T.G., L.G., & M.G., Child., No. 02-15-00147-CV (Tex. App.—Fort Worth July 17, 2015).published See E.C.R., 402 S.W.3d at 249 (“Many of the reasons supporting termination under [section 161.001(b)(1)] also support the trial court’s best- interest finding.”).
- in the Interest of K.M.-J. AKA K.M-J & D.A.R.-J. v. Dep't of Fam. & Prot. Servs., No. 01-15-00253-CV (Tex. App.—Houston [1st Dist.] June 2, 2015).published In re E.C.R., 402 S.W.3d at 249 (“many of the factors supporting termination under subsection O also support the trial court’s best interest finding.”) Archield testified mother completed all the requirements of her FSP.7 She also stated t…
- in the Interest of M.L.G.J., T.M.J., T.L.W.Jr., M.A.J., T.P.R.J., B.W.D. III, M.R.J., L.C.J., Child., No. 14-14-00800-CV, 2015 WL 1402652 (Tex. App.—Houston [14th Dist.] Mar. 24, 2015).published See In re E.C.R., 402 S.W.3d at 249 (“Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding.”); see also In re E.A.F., 424 S.W.3d at 752 (considering the failure to participate i…
- In the Interest of M.T., H.T., R.T., K.T., & G.T., Child. v. the State of Texas, No. 02-26-00186-CV (Tex. App.—Fort Worth Sept. 17, 2026).publishedIn re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of L.Q.-W., L.W., & L.W., Child. v. the State of Texas, No. 02-26-00228-CV (Tex. App.—Fort Worth Aug. 13, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of D.R.S., D.M.F., & D.L.F, Child. v. the State of Texas, No. 07-25-00407-CV (Tex. App.—Amarillo Aug. 10, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of M.M. & M.M., Child. v. the State of Texas, No. 07-26-00099-CV (Tex. App.—Amarillo June 29, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of I.G., a Child v. the State of Texas, No. 07-26-00094-CV (Tex. App.—Amarillo June 16, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of B.A. & B.A., Child. v. the State of Texas, No. 02-26-00055-CV (Tex. App.—Fort Worth June 4, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
Show 187 more citing cases
- In the Interest of D.J., a Child v. the State of Texas, No. 02-26-00022-CV (Tex. App.—Fort Worth Apr. 30, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of A.S., a Child v. the State of Texas, No. 02-25-00645-CV (Tex. App.—Fort Worth Apr. 16, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of J.D., R.D.-G., K.G., & L.G., Child. v. the State of Texas, No. 02-25-00574-CV (Tex. App.—Fort Worth Mar. 26, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of J.E.H., a Child v. the State of Texas, No. 07-25-00405-CV (Tex. App.—Amarillo Mar. 25, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of K.N., M.N., & M.N., Child. v. the State of Texas, No. 02-25-00438-CV (Tex. App.—Fort Worth Feb. 19, 2026).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of N.L., a Child v. the State of Texas, No. 02-25-00205-CV, 2025 WL 3008022 (Tex. App.—Fort Worth Oct. 27, 2025).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of H.M.L., & D.J.C., Child. v. the State of Texas, No. 07-25-00092-CV (Tex. App.—Amarillo July 30, 2025).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of L.C., a Child v. the State of Texas, No. 02-24-00510-CV (Tex. App.—Fort Worth June 26, 2025).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of D.S., D.S., D.S., & D.B., Child. v. the State of Texas, No. 02-25-00124-CV (Tex. App.—Fort Worth June 19, 2025).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- In the Interest of B.C., a Child v. the State of Texas, No. 02-24-00541-CV (Tex. App.—Fort Worth May 22, 2025).published In re E.C.R., 402 S.W.3d 239, 250 (Tex. 2013).
- in the Interest of A.L.W. & A.N.W., Minor Child., No. 01-14-00805-CV (Tex. App.—Houston [1st Dist.] May 10, 2015).published
- in the Interest of S.B., T.B., A.B., & K.B., Child., No. 02-18-00310-CV (Tex. App.—Fort Worth Mar. 28, 2019).published
- in the Interest of M.M., a Child, No. 02-18-00337-CV (Tex. App.—Fort Worth Apr. 11, 2019).published
- in the Interest of Z.S., Child, No. 02-18-00335-CV (Tex. App.—Fort Worth Apr. 18, 2019).published
- in the Interest of S.S., a Child, No. 02-18-00353-CV (Tex. App.—Fort Worth Apr. 18, 2019).published
- in the Interest of S.C., a Child, No. 02-18-00422-CV (Tex. App.—Fort Worth June 13, 2019).published
- in the Interest of A.B.-G. & A.B.-G., Child., No. 02-19-00066-CV (Tex. App.—Fort Worth Aug. 8, 2019).published
- in the Interest of K.A., a Child, No. 02-19-00099-CV, 2019 WL 4309168 (Tex. App.—Fort Worth Sept. 12, 2019).published
- in the Interest of K.H., Q.H., Q.H., & S.R., Child., No. 02-19-00247-CV (Tex. App.—Fort Worth Nov. 22, 2019).published
- in the Interest of T.C., a Child, No. 02-19-00291-CV (Tex. App.—Fort Worth Dec. 5, 2019).published
- in the Interest of M.R., a Child, No. 02-19-00212-CV (Tex. App.—Fort Worth Jan. 14, 2020).published
- in the Interest of B.B., a Child, No. 02-19-00250-CV (Tex. App.—Fort Worth Mar. 5, 2020).published
- in the Interest of G.S., a Child, No. 02-19-00390-CV (Tex. App.—Fort Worth Mar. 19, 2020).published
- in the Interest of J v. a Child, No. 02-19-00392-CV (Tex. App.—Fort Worth Apr. 1, 2020).published
- in the Interest of A.S. & S.S., Child., No. 02-19-00429-CV, 2020 WL 2071944 (Tex. App.—Fort Worth Apr. 30, 2020).published
- in the Interest of H.L., a Child, No. 02-20-00120-CV (Tex. App.—Fort Worth Oct. 8, 2020).published
- in the Interest of M.S. & S.S., Child., No. 02-20-00147-CV (Tex. App.—Fort Worth Oct. 15, 2020).published
- in the Interest of T.R., T.R., & R.N.-R., Child., No. 02-20-00359-CV (Tex. App.—Fort Worth Apr. 15, 2021).published
- in the Interest of R.H., F v. M v. & P.H., Child., No. 02-20-00396-CV (Tex. App.—Fort Worth May 20, 2021).published
- in the Interest of J.G., a Child, No. 02-21-00020-CV (Tex. App.—Fort Worth July 15, 2021).published
- in the Interest of A.W., a Child, No. 02-21-00058-CV (Tex. App.—Fort Worth July 29, 2021).published
- in the Interest of M.M. & E.L., Child., No. 02-21-00185-CV (Tex. App.—Fort Worth Nov. 10, 2021).published
- A. W. v. Texas Dep't of Fam. & Prot. Servs., No. 03-21-00324-CV (Tex. App.—Austin Dec. 15, 2021).published
- in the Interest of J.B., a Child, No. 02-21-00239-CV (Tex. App.—Fort Worth Dec. 30, 2021).published
- in the Interest of B.H. A/K/A M.O., a Child, No. 02-21-00233-CV (Tex. App.—Fort Worth Jan. 6, 2022).published
- in the Interest of C.W. & M.W., Child., No. 02-21-00252-CV (Tex. App.—Fort Worth Jan. 13, 2022).published
- in the Interest of A.G., a Child, No. 02-21-00297-CV (Tex. App.—Fort Worth Feb. 17, 2022).published
- in the Interest of J.M. & J.M., Child., No. 02-21-00346-CV (Tex. App.—Fort Worth Mar. 24, 2022).published
- in the Interest of E.M., a Child, No. 02-21-00326-CV (Tex. App.—Fort Worth Mar. 24, 2022).published
- in the Interest of I.B., Jr., a Child, No. 02-21-00358-CV, 2022 WL 1257133 (Tex. App.—Fort Worth Apr. 28, 2022).published
- in the Interest of M. H., a Child, No. 02-22-00048-CV (Tex. App.—Fort Worth July 21, 2022).published
- in the Interest of S.W., a Child, No. 02-22-00097-CV (Tex. App.—Fort Worth Aug. 25, 2022).published
- in the Interest of A.I., a Child, No. 02-22-00176-CV (Tex. App.—Fort Worth Sept. 22, 2022).published
- in the Interest of C.B., C.B., & K.B., Child., No. 02-22-00212-CV (Tex. App.—Fort Worth Oct. 27, 2022).published
- in the Interest of A.P., B.P., D.P., & A.P., Child., No. 02-22-00180-CV (Tex. App.—Fort Worth Nov. 3, 2022).published
- in the Interest of E.B., a Child, No. 02-22-00205-CV (Tex. App.—Fort Worth Nov. 23, 2022).published
- in the Interest of D.A., D.A., C.A., S.A., & C.A., Child., No. 02-22-00260-CV, 2022 WL 17841133 (Tex. App.—Fort Worth Dec. 22, 2022).published
- in the Interest of A.C., D.C., & L.C., Child., No. 02-22-00321-CV (Tex. App.—Fort Worth Jan. 26, 2023).published
- In the Interest of K.A., M.A., & P.G., Child. v. the State of Texas, No. 02-22-00442-CV (Tex. App.—Fort Worth Mar. 9, 2023).published
- In the Interest of D.W., K.W. & L.W., Child. v. the State of Texas, No. 02-22-00478-CV (Tex. App.—Fort Worth May 11, 2023).published
- In the Interest of G.M. & A.M., Child. v. the State of Texas, No. 02-23-00044-CV (Tex. App.—Fort Worth May 25, 2023).published
- In the Interest of M.G., a Child v. the State of Texas, No. 02-23-00074-CV, 2023 WL 4008687 (Tex. App.—Fort Worth June 15, 2023).published
- In the Interest of G.M., a Child v. the State of Texas, No. 02-23-00061-CV (Tex. App.—Fort Worth June 29, 2023).published
- In the Interest of J.E. & A.E., Child. v. the State of Texas, No. 02-23-00141-CV (Tex. App.—Fort Worth Aug. 10, 2023).published
- In the Interest of S v. J v. & K v. Child. v. the State of Texas, No. 02-23-00188-CV (Tex. App.—Fort Worth Sept. 14, 2023).published
- In the Interest of D.R., R.R., A.R., & J.R., Child. v. the State of Texas, No. 02-23-00093-CV (Tex. App.—Fort Worth Sept. 14, 2023).published
- In the Interest of B.U., a Child v. the State of Texas, No. 02-23-00150-CV, 2023 WL 5967604 (Tex. App.—Fort Worth Sept. 14, 2023).published
- In the Interest of K.J. & C.W., Child. v. the State of Texas, No. 02-23-00198-CV (Tex. App.—Fort Worth Oct. 5, 2023).published
- In the Interest of E.J., B.J., K.C. & K.C., Child. v. the State of Texas, No. 02-23-00113-CV (Tex. App.—Fort Worth Oct. 5, 2023).published
- In the Interest of P.P.-S., & G.P.-S., Child. v. the State of Texas, No. 02-23-00309-CV, 2024 WL 123654 (Tex. App.—Fort Worth Jan. 11, 2024).published
- In the Interest of B. J. F. v. Dep't of Fam. & Prot. Servs., No. 01-23-00522-CV, 2024 WL 117174 (Tex. App.—Houston [1st Dist.] Jan. 11, 2024).published
- In the Interest of P.M. & A.M., Child. v. the State of Texas, No. 02-23-00365-CV (Tex. App.—Fort Worth Mar. 7, 2024).published
- In the Interest of H.S., B.S., & M.S., Child. v. the State of Texas, 710 S.W.3d 248 (Tex. App.—Fort Worth 2024).published
- In the Interest of J.C.D.Y. AKA J.Y., J.E.D.Y. AKA J.Y., M.M.D.Y. AKA M.Y., I.E.J. AKA I.J., M.D.K.G. AKA M.Y. AKA M.O.D.Y., & J.T.D.Y. AKA J.Y., Child. v. Dep't of Fam. & Prot. Servs., No. 01-23-00713-CV, 2024 WL 1334334 (Tex. App.—Houston [1st Dist.] Mar. 29, 2024).published
- In the Interest of H.C., a Child v. the State of Texas, No. 02-23-00477-CV, 2024 WL 1561513 (Tex. App.—Fort Worth Apr. 11, 2024).published
- In the Interest of A.S., a Child v. the State of Texas, No. 02-24-00072-CV (Tex. App.—Fort Worth May 30, 2024).published
- In the Interest of N.M. & H.M., Child. v. the State of Texas, No. 02-24-00062-CV (Tex. App.—Fort Worth June 13, 2024).published
- In the Interest of J.G., J.G., J.G., & J.Z., Child. v. the State of Texas, No. 02-24-00022-CV (Tex. App.—Fort Worth June 13, 2024).published
- In the Interest of K.W., a Child v. the State of Texas, No. 02-24-00082-CV (Tex. App.—Fort Worth July 18, 2024).published
- In the Interest of A.M., a Child v. the State of Texas, No. 02-24-00199-CV (Tex. App.—Fort Worth Sept. 12, 2024).published
- In the Interest of J.H., A.H., & S.H., Child. v. the State of Texas, No. 02-24-00215-CV (Tex. App.—Fort Worth Oct. 17, 2024).published
- In the Interest of W.H., V.H., E.H., & C.R., Child. v. the State of Texas, No. 02-24-00291-CV (Tex. App.—Fort Worth Nov. 7, 2024).published
- In the Interest of J.D., J.D., E.R., M.R., & G.R., Child. v. the State of Texas, No. 02-24-00404-CV, 2025 WL 52128 (Tex. App.—Fort Worth Jan. 9, 2025).published
- In the Interest of I.A. & A.A., Child. v. the State of Texas, No. 02-24-00471-CV (Tex. App.—Fort Worth Feb. 13, 2025).published
- In the Interest of L.I., a Child v. the State of Texas, No. 02-24-00445-CV (Tex. App.—Fort Worth Mar. 6, 2025).published
- In the Interest of A.W., M.B. & J.B., Child. v. the State of Texas, No. 02-24-00544-CV (Tex. App.—Fort Worth Apr. 3, 2025).published
- in the Interest of K.M. A/K/A K v. a Child, No. 02-14-00376-CV (Tex. App.—Fort Worth Mar. 23, 2015).published
- in the Interest of E.G. & E.S., Child., No. 02-14-00351-CV (Tex. App.—Fort Worth Mar. 23, 2015).published
- in the Interest of G.H., a Child, No. 02-14-00261-CV, 2015 WL 3827703 (Tex. App.—Fort Worth June 19, 2015).published
- in the Interest of S.D. & I.D., Child., No. 02-15-00165-CV (Tex. App.—Fort Worth Sept. 10, 2015).published
- in the Interest of T.L.R & T.J.R., Child., No. 14-14-00812-CV (Tex. App.—Houston [14th Dist.] Apr. 2, 2015).published
- in the Interest of R.S. & A.S., Child., No. 02-15-00137-CV (Tex. App.—Fort Worth Oct. 1, 2015).published
- in the Interest of L.A.A., L.B.A., & K.S., No. 04-14-00654-CV (Tex. App.—San Antonio Mar. 11, 2015).published
- in the Interest of K.H., S.W., & I.W., Child., No. 02-15-00164-CV (Tex. App.—Fort Worth Oct. 15, 2015).published
- in the Interest of M.H., II, a Child, No. 02-15-00263-CV (Tex. App.—Fort Worth Feb. 5, 2016).published
- in the Interest of D.R.L., C.L.W., Jr., & A.E.L., Child., No. 01-15-00733-CV, 2016 WL 672664 (Tex. App.—Houston [1st Dist.] Feb. 18, 2016).published
- in the Interest of I.C., N.C., A.C., & D.C., Child., No. 02-15-00300-CV (Tex. App.—Fort Worth Apr. 7, 2016).published
- in the Interest of A.S., a Child, No. 02-16-00076-CV (Tex. App.—Fort Worth June 16, 2016).published
- in the Interest of A.W.G. Jr., a Child, No. 14-16-00071-CV (Tex. App.—Houston [14th Dist.] July 7, 2016).published
- in the Interest of J.W., a Child, No. 02-16-00068-CV (Tex. App.—Fort Worth Aug. 4, 2016).published
- in the Interest of L.S., a Child, No. 02-16-00197-CV (Tex. App.—Fort Worth Sept. 8, 2016).published
- In re M.F.D., No. 01-16-00295-CV (Tex. App.—Houston [1st Dist.] Sept. 22, 2016).published
- in the Interest of R.H., M.D.J. & M.K. Child. v. Dep't of Fam. & Prot. Servs., No. 01-14-00874-CV (Tex. App.—Houston [1st Dist.] May 1, 2015).published
- in the Interest of A.A.L.A, F.K.A, & C.M.A., Child., No. 14-15-00265-CV (Tex. Sept. 15, 2015).published
- in the Interest of X.F.H., Z.T.A.A. & J.D.K., Child., No. 14-15-00492-CV (Tex. Nov. 10, 2015).published
- in the Interest of D.A. & S.G., Child., No. 02-15-00213-CV (Tex. App.—Fort Worth Dec. 10, 2015).published
- in the Interest of M.T., a Child, No. 05-15-00838-CV (Tex. App.—Dallas Sept. 2, 2015).published
- in the Interest of O.D.H., a Child, No. 14-15-00489-CV (Tex. App.—Houston [14th Dist.] Nov. 10, 2015).published
- in the Interest of L.M., a Child, No. 02-16-00127-CV (Tex. App.—Fort Worth Oct. 13, 2016).published
- in the Interest of L.T.B. & L.M.A., Child., No. 14-16-00384-CV (Tex. App.—Houston [14th Dist.] Nov. 3, 2016).published
- In re M.F.D., No. 01-16-00295-CV (Tex. App.—Houston [1st Dist.] Dec. 8, 2016).published
- in the Interest of A. D. N., M. D. N., D. J. N. & M. M. T. N. , Child., No. 01-16-00785-CV (Tex. App.—Houston [1st Dist.] Feb. 7, 2017).published
- in the Interest of P.S. & C.S., Minor Child., No. 02-16-00458-CV (Tex. App.—Fort Worth Mar. 30, 2017).published
- in the Interest of L.A., a Child, No. 02-16-00403-CV (Tex. App.—Fort Worth Apr. 6, 2017).unpublished
- in the Interest of A.T., a Child, No. 02-17-00230-CV (Tex. App.—Fort Worth Oct. 26, 2017).published
- in the Interest of S.N.T.S. v. Dep't of Fam. & Prot. Servs., No. 14-17-00463-CV (Tex. App.—Houston [14th Dist.] Nov. 16, 2017).published
- in the Interest of A.F.G., B.N.G., A.M.G., & J.L.G. Jr., Child., No. 14-17-00440-CV (Tex. App.—Houston [14th Dist.] Nov. 16, 2017).published
- in the Interest of J. S.- A. S AKA J. S., J. B. S., Jr., Child., No. 01-17-00491-CV (Tex. App.—Houston [1st Dist.] Dec. 5, 2017).published
- in the Interest of G.T., a Child, No. 02-17-00279-CV (Tex. App.—Fort Worth Dec. 28, 2017).published
- in the Interest of N.M.L. & B.L.L., Child., No. 07-17-00310-CV, 2018 Tex. App. LEXIS 607 (Tex. App.—Amarillo Jan. 19, 2018).published
- in the Interest of A.D.J., a Child, No. 04-17-00664-CV (Tex. App.—San Antonio Mar. 21, 2018).published
- in the Interest of L.L.C., Child v. Dep't of Fam. & Prot. Servs., No. 01-17-00961-CV (Tex. App.—Houston [1st Dist.] June 7, 2018).published
- in the Interest of K.M., a Child, No. 02-18-00073-CV (Tex. App.—Fort Worth July 5, 2018).published
- in the Interest of J.B., a Child, No. 02-18-00034-CV (Tex. App.—Fort Worth July 5, 2018).published
- in the Interest of R.M., C.S., I.S., & T.M., Child., No. 02-18-00077-CV (Tex. App.—Fort Worth July 19, 2018).published
- in the Interest of G.M., a Child, No. 02-18-00128-CV (Tex. App.—Fort Worth July 19, 2018).published
- in the Interest of N.F., a Child, No. 07-18-00104-CV (Tex. App.—Amarillo Aug. 1, 2018).published
- in the Interest of G.H. & G.H., Child., No. 02-18-00080-CV (Tex. App.—Fort Worth Aug. 16, 2018).published
- in the Interest of F.H., a Child, No. 14-18-00209-CV (Tex. App.—Houston [14th Dist.] Aug. 21, 2018).published
- in the Interest of P.L.G. & H.M.G., Child., No. 07-18-00206-CV (Tex. App.—Amarillo Aug. 28, 2018).published
- in the Interest of D.N.M., I.S.C., R.L.L., Child., No. 07-18-00251-CV (Tex. App.—Amarillo Sept. 13, 2018).published
- in the Interest of Z.W., a Child, No. 02-18-00190-CV (Tex. App.—Fort Worth Sept. 13, 2018).published
- in the Interest of E.T., a Child, No. 07-18-00254-CV (Tex. App.—Amarillo Sept. 18, 2018).published
- in the Interest of K.S. & E.S., Child., No. 02-18-00191-CV (Tex. App.—Fort Worth Sept. 28, 2018).published
- in the Interest of A.W., a Child, No. 02-18-00147-CV (Tex. App.—Fort Worth Oct. 18, 2018).published
- in the Interest of A.C., a Child, No. 02-18-00129-CV (Tex. App.—Fort Worth Oct. 24, 2018).published
- in the Interest of I.L., a Child, No. 02-18-00206-CV (Tex. App.—Fort Worth Nov. 1, 2018).published
- in the Interest of N.J.H., Child. v. Dep't of Fam. & Prot. Servs., 575 S.W.3d 822 (Tex. App.—Houston [1st Dist.] 2018).published
- in the Interest of D.I.L.-M. AKA D.M., S.K.D.-M., A.M.Q.-M. AKA A.M.B. & A.J.B.-M., Child., No. 14-18-00526-CV (Tex. App.—Houston [14th Dist.] Dec. 4, 2018).published
At page 248 Interpreting abuse or neglect in child removal statutes84 citing cases“necessarily includes the risks or threats of the environment in which the child is placed.”
- S. L. & J. R. v. Texas Dep't of Fam. & Prot. Servs., No. 03-22-00722-CV (Tex. App.—Austin May 18, 2023).published(So while subsection O requires removal under chapter 262 for abuse or neglect, those words are used broadly.)
- In the Interest of L.M.W., a Child v. the State of Texas, No. 04-22-00577-CV (Tex. App.—San Antonio Mar. 6, 2023).published See In re E.C.R., 402 S.W.3d 239, 246 (Tex. 2013) (“We agree that subsection (O) requires proof of abuse or neglect, but we disagree that those terms can never be read to include risk.”).
- 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, Child. v. Texas Dep't of Fam. & Prot. Servs., No. 14-21-00427-CV (Tex. App.—Houston [14th Dist.] Mar. 10, 2022).published([W]hile subsection O requires removal under Chapter 262 for abuse or neglect, those words are used broadly.)
- in the Interest of J.M, B.L.U., B. L.U., K.U. Child., No. 01-15-00525-CV (Tex. App.—Houston [1st Dist.] Aug. 17, 2015).published([The removal] affidavit, even if not evidence for all purposes, shows what the trial court relied on in determining whether removal was justified.)
- in the Interest J. R. W., a Child, No. 01-14-00442-CV (Tex. App.—Houston [1st Dist.] Nov. 26, 2014).published (If a parent has neglected, sexually abused, or otherwise endangered her child’s physical health or safety, such that initial and continued removal are appropriate, the child has been ‘remov[ed] from the parent under Ch…)
- In re N.G., 575 S.W.3d 370 (Tex. App.—Dallas 2018).published (Consistent with chapter 262's removal standards, 'abuse or neglect of the child' necessarily includes the risks or threats of the environment in which the child is placed.)
- In the Interest of A. C. K. A/K/A A. K. v. Dep't of Fam. & Prot. Servs., No. 01-23-00697-CV (Tex. App.—Houston [1st Dist.] Mar. 21, 2024).published
- in the Interest of T. L. B. Jr. AKA T. B., No. 01-16-00806-CV (Tex. App.—Houston [1st Dist.] Mar. 16, 2017).published
- M. D. v. Texas Dep't of Fam. & Prot. Servs., No. 03-20-00531-CV (Tex. App.—Austin Apr. 30, 2021).published
- in the Interest of P.H., a Child, No. 05-22-00617-CV, 2022 WL 17663648 (Tex. App.—Dallas Dec. 14, 2022).published
Show 73 more citing cases
- In the Interest of J.M.F., Jr., a Child v. the State of Texas, No. 14-22-00628-CV, 2023 WL 2182435 (Tex. App.—Houston [14th Dist.] Feb. 23, 2023).published
- in the Interest of T. W., a Child, No. 13-14-00318-CV (Tex. App.—Corpus Christi Dec. 3, 2014).published
- in the Interest of E.N.A., A.A., J.J.P. & M.P., Child., No. 11-14-00345-CV (Tex. App.—Eastland June 11, 2015).published
- in the Interest of R.C., No. 04-15-00082-CV (Tex. App.—San Antonio July 8, 2015).published
- in the Interest of R.E.T.R. & D.D.R., Jr., Child., No. 14-13-00640-CV, 2013 WL 6506689 (Tex. App.—Houston [14th Dist.] Dec. 10, 2013).published
- in the Interest of C.C.C. & C.S.C., Child., No. 11-14-00252-CV (Tex. App.—Eastland Mar. 12, 2015).published
- in the Interest of J.F., a Child, No. 11-14-00246-CV (Tex. App.—Eastland Mar. 6, 2015).published
- in the Interest of C.S., a Child, No. 02-14-00386-CV (Tex. App.—Fort Worth Apr. 23, 2015).published
- in the Interest of A.H., No. 09-13-00395-CV (Tex. App.—Beaumont Apr. 10, 2014).published
- in the Interest of B.P., a Child, No. 07-14-00037-CV (Tex. App.—Amarillo July 25, 2014).published
- in the Interest of A.Y. & P.J.T., Child., No. 10-13-00209-CV (Tex. App.—Waco Dec. 12, 2013).published
- in the Interest of N.M., a Child, No. 07-13-00325-CV (Tex. App.—Amarillo Feb. 21, 2014).published
- in the Interest of A.T., A.T., & A.T., Child., No. 07-13-00166-CV (Tex. App.—Amarillo Oct. 10, 2013).published
- in the Interest of A. S. v. Dep't of Fam. & Prot. Servs., No. 01-14-00113-CV (Tex. App.—Houston [1st Dist.] July 31, 2014).published
- in the Interest of T.M.D, Jr., B.M.D., Z.T.D & E.M.D. Child., No. 01-13-00970-CV (Tex. App.—Houston [1st Dist.] May 6, 2014).published
- in the Interest of A.A., D.A. & J.A., Child., No. 01-13-00542-CV (Tex. App.—Houston [1st Dist.] Dec. 12, 2013).published
- in the Interest of T.W., a Child, No. 05-16-00232-CV, 2016 WL 3437589 (Tex. App.—Dallas June 21, 2016).published
- in the Interest of Z.B. & Z.B., Child., No. 07-16-00026-CV (Tex. App.—Amarillo July 12, 2016).published
- in the Interest of S.D., L.D., A.D., & J.E., Child., No. 07-16-00085-CV (Tex. App.—Amarillo July 29, 2016).published
- in the Interest of J.H., No. 09-15-00171-CV, 2015 WL 5093400 (Tex. App.—Beaumont Aug. 31, 2015).published
- in the Interest of K.J.G., a Child, No. 11-15-00132-CV (Tex. App.—Eastland Dec. 3, 2015).published
- in the Interest of J.D.P., a Child, No. 11-15-00148-CV (Tex. App.—Eastland Dec. 17, 2015).published
- in the Interest of A.M.D., a Child, No. 07-15-00134-CV (Tex. App.—Amarillo July 30, 2015).published
- in the Interest of A.L.W. & A.N.W., Minor Child., No. 01-14-00805-CV (Tex. App.—Houston [1st Dist.] May 10, 2015).published
- in the Interest of A.B., a Child, No. 07-15-00197-CV (Tex. App.—Amarillo Oct. 21, 2015).published
- in the Interest of S.F., a Child, No. 11-16-00096-CV (Tex. App.—Eastland Sept. 30, 2016).published
- in the Interest of C.C., J.C., Jr., J.J.C., & E.C., Child., No. 10-16-00129-CV, 2016 Tex. App. LEXIS 12277 (Tex. App.—Waco Nov. 16, 2016).published
- in the Interest of D.M.M., Child, No. 14-16-00664-CV, 2017 WL 61847 (Tex. App.—Houston [14th Dist.] Jan. 5, 2017).published
- in the Interest of E.M.H., a Child, No. 11-16-00254-CV (Tex. App.—Eastland Mar. 3, 2017).published
- in the Interest of Z. J. R., a Child, No. 13-17-00273-CV (Tex. App.—Corpus Christi Nov. 16, 2017).published
- in the Interest of I.G., a Child, No. 04-17-00554-CV (Tex. App.—San Antonio Jan. 17, 2018).published
- in the Interest of S.A., a Child, No. 04-17-00571-CV (Tex. App.—San Antonio Jan. 24, 2018).published
- in the Interest of S.E.S., a Child, No. 04-17-00847-CV (Tex. App.—San Antonio May 30, 2018).published
- in the Interest of N.J.T. & V.G.T., No. 04-18-00068-CV (Tex. App.—San Antonio June 13, 2018).published
- in the Interest of Z.A., A.A., & R.L., Child., No. 11-18-00010-CV (Tex. App.—Eastland July 17, 2018).published
- in the Interest of B.K. & G.L., Child., No. 06-18-00037-CV, 2018 WL 3892860 (Tex. App.—Texarkana Aug. 16, 2018).published
- in the Interest of B.C., a Child, No. 11-18-00098-CV (Tex. App.—Eastland Sept. 27, 2018).published
- in the Interest of J.B. A/K/A J.D., a Child, No. 02-18-00173-CV (Tex. App.—Fort Worth Sept. 27, 2018).published
- in the Interest of A.M.L.M., T.W.M., S.L.M., Child., No. 13-18-00527-CV (Tex. App.—Corpus Christi Mar. 14, 2019).published
- in the Interest of L.M., a Child, 572 S.W.3d 823 (Tex. App.—Houston [14th Dist.] 2019).published
- in the Interest of C.R., A.R., & I.R., Child., No. 07-19-00009-CV (Tex. App.—Amarillo Apr. 16, 2019).published
- in the Interest of A.H., No. 09-19-00025-CV (Tex. App.—Beaumont May 23, 2019).published
- in the Interest of Z.L.C., a Child, No. 11-18-00345-CV (Tex. App.—Eastland May 31, 2019).published
- in the Interest of P.N.T., a Child v. Texas Dep't of Fam. & Prot. Servs., No. 14-18-01115-CV, 2019 WL 2426692 (Tex. App.—Houston [14th Dist.] June 11, 2019).published
- in the Interest of M.G., a Child, No. 11-18-00351-CV (Tex. App.—Eastland June 11, 2019).published
- in the Interest of A.H., F.H., K.H., & C.H., Child., No. 11-19-00028-CV (Tex. App.—Eastland July 18, 2019).published
- in the Interest of Z.B. & S.B., Child., No. 10-19-00135-CV (Tex. App.—Waco Sept. 11, 2019).published
- in the Interest of S.B., a Child, No. 07-19-00146-CV (Tex. App.—Amarillo Nov. 5, 2019).published
- in the Interest of A.J.W., J.W. Jr., R.L.A.W., & J.L.W., No. 04-19-00346-CV (Tex. App.—San Antonio Nov. 27, 2019).published
- A. B. v. Texas Dep't of Fam. & Prot. Servs., No. 03-19-00593-CV (Tex. App.—Austin Feb. 5, 2020).published
- in the Interest of M.G. & M.G., III, Child., No. 07-19-00289-CV (Tex. App.—Amarillo Feb. 7, 2020).published
- in the Interest of M. W., a Child, No. 13-19-00593-CV (Tex. App.—Corpus Christi–Edinburg Apr. 16, 2020).published
- in the Interest of N.N.M., a Child, No. 04-19-00369-CV (Tex. App.—San Antonio Aug. 19, 2020).published
- in the Interest of E.K. & G.K., Child., No. 11-20-00160-CV (Tex. App.—Eastland Jan. 14, 2021).published
- in the Interest of D.F.S., C.S.S., & C.R.S., Child., No. 04-20-00441-CV, 2021 WL 603364 (Tex. App.—San Antonio Feb. 17, 2021).published
- in the Interest of A.L.R., a Child, No. 11-20-00294-CV (Tex. App.—Eastland June 24, 2021).published
- in the Interest of B.C.C. & K.M.C., Child., No. 05-21-00091-CV (Tex. App.—Dallas June 30, 2021).published
- T. M. & O. A. v. Texas Dep't of Fam. & Prot. Servs., No. 03-21-00174-CV (Tex. App.—Austin Oct. 8, 2021).published
- in the Interest of C.A.L. A/K/A C.L. v. a Child v. Texas Dep't of Fam. & Prot. Servs., No. 14-21-00543-CV, 2022 WL 553168 (Tex. App.—Houston [14th Dist.] Feb. 24, 2022).published
- in the Interest of L.P., a Child, No. 04-22-00015-CV (Tex. App.—San Antonio June 22, 2022).published
- R. J. & A. D. M. v. Texas Dep't of Fam. & Prot. Servs., No. 03-22-00190-CV (Tex. App.—Austin Sept. 15, 2022).published
- in the Interest of M.R. & X.R., Child., No. 13-22-00304-CV, 2022 WL 17844215 (Tex. App.—Corpus Christi–Edinburg Dec. 22, 2022).published
- in the Interest of D.L.W., Jr. & E.W., Child. v. Texas Dep't of Fam. & Prot. Servs., No. 14-22-00654-CV, 2023 WL 1460548 (Tex. App.—Houston [14th Dist.] Feb. 2, 2023).published
- In the Interest of R.A.B. Jr & M.M.G-B, Child. v. the State of Texas, No. 08-22-00247-CV, 2023 WL 3672050 (Tex. App.—El Paso May 25, 2023).published
- S. S. F. v. Texas Dep't of Fam. & Prot. Servs., No. 03-23-00243-CV (Tex. App.—Austin Sept. 27, 2023).published
- In the Interest of F.S.F., a Child v. the State of Texas, No. 04-24-00125-CV, 2024 WL 3800662 (Tex. App.—San Antonio Aug. 14, 2024).published
- In the Interest of X.M.B.E., a Child v. the State of Texas, 706 S.W.3d 714 (Tex. App.—Eastland 2025).published
- In the Interest of A.B., a Child v. the State of Texas, No. 11-24-00206-CV (Tex. App.—Eastland Feb. 6, 2025).published
- in the Interest of C.C.B., a Child, No. 11-14-00100-CV (Tex. App.—Eastland Oct. 8, 2014).published
- in the Interest of K.N.D., a Child, No. 01-12-00584-CV, 2014 WL 3970642 (Tex. App.—Houston [1st Dist.] Aug. 14, 2014).published
- in the Interest of K.R.G., Jr., a Child, No. 11-16-00025-CV (Tex. App.—Eastland July 20, 2016).published
- in the Interest of A.M. & B.T., No. 09-18-00295-CV (Tex. App.—Beaumont Jan. 10, 2019).published
- In the Interest of J.S., A/K/A J.T.S., H.S., A/K/A H.L.S., Jr., J.S., A/K/A J.D.S., A.S., A/K/A A.J.S., Child. v. the State of Texas, No. 14-22-00723-CV (Tex. App.—Houston [14th Dist.] Mar. 14, 2023).published
At page 240 Defining service plans and termination of parental rights32 citing casestermination of parental rights based on abuse or neglect, not involving negligence
- in the Interest of M.S., a Child, No. 01-15-00451-CV (Tex. App.—Houston [1st Dist.] Sept. 29, 2015).published See In re C.H., 89 S.W.3d at 28 (holding that same evidence may be probative of both section 161.001(1) predicate grounds and best interest); see also In re E.C.R., 402 S.W.3d at 249 (“Many of the reasons supporting termination under subse…
- In the Interest of K.N., K.L., K.L., & K.L., Child., No. 24-0881, 2026 WL 1614378 (Tex. June 5, 2026).published Further, it isolates other evidence 11 In re E.C.R., 402 S.W.3d 239, 240 (Tex. 2013) (alteration in original) (quoting In re C.H., 89 S.W.3d 17, 26 (Tex. 2002)). 12 In re J.F.C., 96 S.W.3d 256 , 265–66 (Tex. 2002). 13 In re J.F.-G., 627 S.…
- in the Interest of D. P., a Child, No. 13-14-00325-CV (Tex. App.—Corpus Christi Nov. 7, 2014).published
- in the Interest of S. S., a Child, No. 13-14-00433-CV (Tex. App.—Corpus Christi Jan. 19, 2015).published
- in the Interest of A.L.W. & A.N.W., Minor Child., No. 01-14-00805-CV, 2015 WL 4262754 (Tex. App.—Houston [1st Dist.] July 14, 2015).published
- in the Interest of D. L. D., Jr., L. L.S., J. J. S., H. N. S., Child. v. Dep't of Fam. & Prot. Servs., No. 01-15-00160-CV (Tex. App.—Houston [1st Dist.] July 23, 2015).published
- in the Interest of S.M.R., G.J.R. & C.N.R., Child., 434 S.W.3d 576 (Tex. 2014).published
- in the Interest of S.P.M., E.A.T., & C.S.T., Child., No. 07-13-00282-CV, 2014 WL 241796 (Tex. App.—Amarillo Jan. 21, 2014).published
- in the Interest of A.D.C. & J.D.C., Child., No. 02-13-00149-CV (Tex. App.—Fort Worth Oct. 3, 2013).published
- in the Interest of K.R.L., a Minor Child, No. 01-14-00213-CV, 2014 WL 3843520 (Tex. App.—Houston [1st Dist.] Aug. 5, 2014).published
Show 22 more citing cases
- in the Interest of KCF, MLM, LMM & AGM, Minor Child., No. 01-13-01078-CV, 2014 WL 2538624 (Tex. App.—Houston [1st Dist.] June 5, 2014).published
- in the Interest of T.J.C., II, a Minor Child, No. 01-15-00589-CV (Tex. App.—Houston [1st Dist.] Nov. 5, 2015).published
- in the Interest of S. R.- M. C., No. 01-15-00556-CV (Tex. App.—Houston [1st Dist.] Nov. 17, 2015).published
- in the Interest of S. R. H., a Minor Child, No. 01-15-00714-CV (Tex. App.—Houston [1st Dist.] Feb. 4, 2016).published
- In the Interest of E.C., a Child v. the State of Texas, No. 05-23-00586-CV (Tex. App.—Dallas Dec. 19, 2023).published
- In the Interest of A. C. K. A/K/A A. K. v. Dep't of Fam. & Prot. Servs., No. 01-23-00697-CV (Tex. App.—Houston [1st Dist.] Mar. 21, 2024).published
At page 246 Defining abuse and neglect broadly to include risk29 citing casesholding that “subsection O requires proof of abuse or neglect[.]
- In the Interest of L.M.W., a Child v. the State of Texas, No. 04-22-00577-CV (Tex. App.—San Antonio Mar. 6, 2023).published (We agree that subsection (O) requires proof of abuse or neglect, but we disagree that those terms can never be read to include risk.)
- in the Interest J. R. W., a Child, No. 01-14-00442-CV (Tex. App.—Houston [1st Dist.] Nov. 26, 2014).published See In re E.C.R., 402 S.W.3d at 248 (“If a parent has neglected, sexually abused, or otherwise endangered her child’s physical health or safety, such that initial and continued removal are appropriate, the child has been ‘remov[ed] from th…
- In the Interest of A. C. K. A/K/A A. K. v. Dep't of Fam. & Prot. Servs., No. 01-23-00697-CV (Tex. App.—Houston [1st Dist.] Mar. 21, 2024).published
- in the Interest of S.D., Jr., a Child, No. 02-14-00171-CV (Tex. App.—Fort Worth Nov. 20, 2014).published
- A. K. v. Texas Dep't of Fam. & Prot. Servs., No. 03-14-00450-CV (Tex. App.—Austin Nov. 21, 2014).published
- T. J. v. Texas Dep't of Fam. & Prot. Servs., No. 03-14-00351-CV (Tex. App.—Austin Nov. 25, 2014).published
- A. E. & J. L. v. Texas Dep't of Fam. & Prot. Servs., No. 03-14-00414-CV (Tex. App.—Austin Dec. 23, 2014).published
- G. N. E.-A. v. Texas Dep't of Fam. & Prot. Servs., No. 03-14-00168-CV (Tex. App.—Austin July 29, 2014).published
- C. L. J. & T. P. v. Texas Dep't of Fam. & Prot. Servs., No. 03-13-00646-CV (Tex. App.—Austin Mar. 20, 2014).published
- Z. L. v. Texas Dep't of Fam. & Prot. Servs., No. 03-13-00598-CV (Tex. App.—Austin Feb. 7, 2014).published
Show 19 more citing cases
- Robert Michael Riley v. State, No. 14-12-00729-CR (Tex. App.—Houston [14th Dist.] Apr. 15, 2014).published
- in the Interest of E.M. & J.M., Child., 494 S.W.3d 209 (Tex. App.—Waco 2015).published
- in the Interest of T.S. & T.S., No. 09-13-00463-CV (Tex. App.—Beaumont Apr. 10, 2014).published
- in the Interest of A.D., a Child, No. 02-14-00085-CV (Tex. App.—Fort Worth July 31, 2014).published
- in the Interest of B.D.M.& S.P.M., Child., No. 02-13-00388-CV (Tex. App.—Fort Worth Apr. 3, 2014).published
- in the Interest of R. M. S. v. Dep't of Fam. & Prot. Servs., No. 01-13-00331-CV, 2013 WL 5637703 (Tex. App.—Houston [1st Dist.] Oct. 11, 2013).published
- in the Interest of S.S., a Child, 471 S.W.3d 915 (Tex. App.—Texarkana 2015).published
- in the Interest of L.E.S., a Child, No. 06-15-00015-CV (Tex. App.—Texarkana Aug. 18, 2015).published
- in the Interest of T. L. B. Jr. AKA T. B., No. 01-16-00806-CV (Tex. App.—Houston [1st Dist.] Mar. 16, 2017).published
- in the Interest of M.K. & V.G., Child., No. 05-18-01297-CV (Tex. App.—Dallas May 29, 2019).published
- in the Interest of A.T., a Child, No. 05-19-00346-CV (Tex. App.—Dallas Aug. 30, 2019).published
- in the Interest of J. G., III, K.G., G. G., Child., No. 12-19-00301-CV (Tex. App.—Tyler Feb. 19, 2020).published
- In re Matthew Berryman & Tabitha Berryman, 629 S.W.3d 453 (Tex. App.—Tyler 2020).published
- M. D. v. Texas Dep't of Fam. & Prot. Servs., No. 03-20-00531-CV (Tex. App.—Austin Apr. 30, 2021).published
- T. M. & O. A. v. Texas Dep't of Fam. & Prot. Servs., No. 03-21-00174-CV (Tex. App.—Austin Oct. 8, 2021).published
- Vision 20/20, Ltd. v. Cameron Builders, Inc., 525 S.W.3d 854 (Tex. App.—Houston [14th Dist.] 2017).published
- in the Interest of E.D.E.L., a Child, No. 05-22-00103-CV (Tex. App.—Dallas July 1, 2022).published
- in the Interest of P.H., a Child, No. 05-22-00617-CV, 2022 WL 17663648 (Tex. App.—Dallas Dec. 14, 2022).published
- In the Interest of J.M.F., Jr., a Child v. the State of Texas, No. 14-22-00628-CV, 2023 WL 2182435 (Tex. App.—Houston [14th Dist.] Feb. 23, 2023).published
At page 247 Procedures for governmental entity child removal and protection6 citing casesholding evidence of risk of abuse or neglect can be sufficient to support a trial court’s finding that a child was removed for abuse or neglect under statutory ground (O)
- In the Interest of L.M.W., a Child v. the State of Texas, No. 04-22-00577-CV (Tex. App.—San Antonio Mar. 6, 2023).published See In re E.C.R., 402 S.W.3d 239, 246 (Tex. 2013) (“We agree that subsection (O) requires proof of abuse or neglect, but we disagree that those terms can never be read to include risk.”).
- In re Barbara Marks, No. 01-16-00229-CV (Tex. App.—Houston [1st Dist.] Aug. 4, 2016).published
- in the Interest of J.D.S., a Child, 494 S.W.3d 387 (Tex. App.—Waco 2015).published
- in the Interest of B. M., & J. M., Child., No. 12-18-00094-CV (Tex. App.—Tyler Oct. 3, 2018).published
- In re C.T., 491 S.W.3d 323 (Tex. 2016).published
- In re M. N. M., 524 S.W.3d 396 (Tex. App.—Houston [14th Dist.] 2017).published
At page 243 Grounds for terminating parental rights under subsection O4 citing casesholding “that subsection O requires proof of abuse or neglect
- City of Houston v. Roger Bates, 406 S.W.3d 539 (Tex. 2013).published
- In re T. E. G. & E. A. G., Child., No. 01-14-00051-CV (Tex. App.—Houston [1st Dist.] May 8, 2014).published
- in the Interest of J. I. G., A. D. G. Child. v. Dep't of Fam. & Prot. Servs., No. 01-18-00023-CV (Tex. App.—Houston [1st Dist.] May 25, 2018).published
- In the Interest of D. G. & A. G., Child. v. the State of Texas, No. 08-25-00180-CV (Tex. App.—El Paso Nov. 24, 2025).published
delivered the opinion of the Court.
We require the State to overcome significant burdens before removing a child from his parent. These impediments are essential to protect the parent’s fundamental liberty interest in the companionship, care, custody, and management of her children. [1] But “[j]ust as it is imperative for courts to recognize the constitutional underpinnings of the parent-child relationship, it is also essential that emotional and physical interests of the child not be sacrificed merely to preserve that right.” In re C.H., 89 S.W.3d 17, 26 (Tex.2002). [2]
The Family Code allows a court to terminate a parent’s rights to her child if the child has been in the State’s custody for at least nine months, and the State proves, by clear and convincing evidence, that the parent failed to comply with a court order that specified what she had to do to get her child back. Tex. Fam.Code § 161.001(1)(O). The provision applies, however, only if the child was removed from the parent under Family Code Chapter 262 for “abuse or neglect of the child.” Id. We must decide whether abuse or neglect includes placing the child’s physical health or safety at substantial risk, as outlined below. Because we conclude that it does, and because the parent’s abuse or neglect of another child is relevant to that determination, we reverse in part the court of appeals’ judgment and remand the case to that court.
1. Background
After M.R. was seen punching and dragging her four-year-old daughter, Y. C., by her ponytail down the street, a witness called the authorities. M.R.’s eight-month-old son, E.C.R., was not present during this incident. The police found that Y.C. had fresh bruising on her face, dried blood inside her nose, cuts on her forehead and lips, and multiple scrapes. The police arrested M.R., who denied causing the injuries but later pleaded guilty to bodily injury to a child, a third-degree felony. The Department of Family and Protective Services received a referral of physical abuse of Y.C., who was sent to live with her father. After its investigation, the Department placed E.C.R., whose paternity was undetermined, with foster parents.
The Department took possession of E.C.R. under Family Code section 262.104, which authorizes possession without a court order if circumstances would lead a person of ordinary prudence and caution to believe that the child faced “an immediate danger to [his] physical health or safety.” Tex. Fam.Code § 262.104. The next day, the Department filed a petition seeking conservatorship of E.C.R. and termination of M.R.’s parental rights. The petition was supported by a six-page affidavit recounting the circumstances necessitating[*241] E.C.R.’s removal. The affidavit described the allegations of physical abuse of Y.C. and also noted that M.R. had a prior CPS case involving physical abuse of an older son, who was in the permanent managing conservatorship of foster parents. M.R. told caseworker Cyntera Donatto that she had twice attempted suicide while spending three days in jail for the incident involving Y.C. After being released from jail, M.R. slept on the streets and left E.C.R. with her boyfriend at his home. M.R. told Donatto that the boyfriend physically abused her and was not stable. A criminal background check revealed that he had been arrested seven times over the past decade for theft, burglary, driving with an invalid license, and evading arrest. The day after she met with M.R., Donatto learned that M.R. had again been incarcerated.
Donatto observed E.C.R. and noted that, unlike Y.C., there were no evident signs that E.C.R. had been physically abused. He appeared clean, healthy, and developmentally on target. But his mother’s history of abusing her other children, her fragile mental state, and her criminal ease and incarceration persuaded Donatto that E.C.R. should not be left in M.R.’s care. Because E.C.R.’s paternity was unknown, the Department sought to be named his temporary managing conservator.
That day, the trial court found that E.C.R. had been removed pursuant to section 262.104 and that he faced a continuing danger to his physical health or safety if returned to M.R. The trial court also found that the nature of the emergency and the continuing danger to E.C.R.’s welfare made his return to M.R. impossible or unreasonable. The court set the matter for a full adversary hearing within fourteen days.
After that hearing the trial court found sufficient evidence to satisfy a person of ordinary prudence and caution that:
(1) there was a danger to the physical health or safety of the child which was caused by an act or failure to act of the person entitled to possession and for the child to remain in the home is contrary to the welfare of the child; (2) the urgent need for protection required the immediate removal of the child and makes efforts to eliminate or prevent the child’s removal impossible or unreasonable; and (3) notwithstanding reasonable efforts to eliminate the need for the child’s removal and enable the child to return home, there is a substantial risk of a continuing danger if the child is returned home.
The court appointed the Department temporary managing conservator and ordered M.R. to comply -with the service plan. See Tex. Fam.Code §§ 263.101-.106. The court warned M.R. that her failure to do so could result in the termination of her parental rights. See id. §§ 161.001(1)(O), 263.106.
At a subsequent status hearing, the trial court signed additional temporary orders setting the conditions for E.C.R.’s return to M.R. M.R. had to complete a psychiatric examination and follow all recommendations; complete a psychological examination and follow all recommendations; participate in counseling, including individual, group, or family therapy sessions; complete parenting classes; complete random drug tests; remain drug free; refrain from engaging in criminal activity; maintain stable housing; maintain stable employment; successfully complete domestic violence and anger management classes; and complete all services outlined in the Family Service Plan. The court found that M.R. reviewed and understood the service plan and was advised that unless she was will[*242] ing and able to provide E.C.R. with a safe environment within the time specified in the plan, her parental rights could be terminated.
Almost a year later, the trial court held a termination hearing. M.R. gave limited testimony. She admitted being served with citation and receiving deferred adjudication for causing injury to a child, but she denied ever telling the caseworker that E.C.R. was not living in a safe environment. She provided the names of two men who might be E.C.R.’s father. She admitted having a prior CPS case that went to final orders, and that she no longer had custody of that child.
The Department representative testified that E.C.R. was removed because of the risk of physical abuse based on M.R.’s abuse of Y.C. The representative also stated that M.R. had completed some of the court-ordered requirements, but she had not satisfied the “big” ones. She failed to undergo a psychiatric evaluation or participate in psychotherapy. The Department also presented evidence that M.R. did not obtain employment, a violation of both the Family Service Plan and the conditions of her community supervision, and she had not lived in a home for six months.
The trial court terminated M.R.’s rights under subsection O of Family Code section 161.001(1), finding that such termination was in E.C.R.’s best interest. M.R. appealed, challenging the sufficiency of the evidence supporting termination under that subsection and the best interest finding. As to the former, her argument was straightforward. She did not dispute her failure to comply with the provisions of a court order that specifically established the actions necessary for E.C.R. to be returned to her and that E.C.R. had been in the Department’s conservatorship for more than nine months. Instead, she argued that termination under subsection O was improper because E.C.R. was removed because of risk of abuse based on her conduct toward his sibling, but not for actual abuse or neglect.
The court of appeals agreed, holding that M.R.’s abuse of Y.C. was not evidence that M.R. abused or neglected E.C.R. 890 S.W.3d 22, 27. Instead, “[f]or a trial court to terminate parental rights under section 161.001(1)(O), it must find that the child who is the subject of the suit was removed as a result of the abuse or neglect of that specific child.” Id. The court noted that “the Family Service Plan and [the caseworker’s] testimony both show that [the Department] became involved as a result of M.R.’s abuse of E.C.R.’s sibling, a factor that the court could not consider in reaching a finding under section 161.001(1)(O).” Id. at 28. The court reversed the portion of the trial court’s judgment terminating M.R.’s parental rights and rendered judgment denying the Department’s termination petition. [3] Id. at 30. A divided court voted against en banc reconsideration. Id. (Keyes, J., dissenting).
We granted the petition for review. 2013 Tex. LEXIS 112 (Feb. 15, 2013).
[*243] II. The Department proved grounds for termination under subsection 161.001(1X0) as a matter of law.
Family Code section 161.001(1) identifies multiple grounds for involuntarily terminating parental rights. Subsection O authorizes termination if the court finds, by clear and convincing evidence, that a parent has:
failed to comply with the provisions of a court order that specifically established the actions necessary for the parent to obtain the return of the child who has been in the permanent or temporary managing conservatorship of the Department of Family and Protective Services for not less than nine months as a result of the child’s removal from the parent under Chapter 262 for the abuse or neglect of the child.
Tex. Fam.Code § 161.001(1)(O).
We last considered subsection O in In re J.F.C., 96 S.W.3d 256, 277 (Tex.2002), an appeal of a judgment terminating the parents’ right to their three children. In that case, the Department received a referral alleging that the father had sexually abused two of the children, but the ensuing investigation revealed no evidence of abuse. In re J.F.C., 57 S.W.3d 66, 68 (Tex.App.-Waco 2001), rev’d, 96 S.W.3d 256 (Tex.2002). A year later, the Department received information that the parents “had drug problems, were physically abusive to one another, and máy have been physically abusing the children.” Id. The Department investigated and found bruises on one of the children, as well as corroboration of drug use in the home. Id. The Department did not remove the children, because it concluded they were not in immediate danger. Id. In weekly home visits over the next seven months, the Department found no evidence of abuse. Id. The Department learned, however, that the parents were not participating in their required counseling and continued to have conflicts among themselves. Id. Subsequently, the Department received a report that the mother had handled one of the children roughly; the Department confirmed that the child (the same one who had bruises previously) had marks and scratches on his body. Id. The Department found that the parents’ emotional health was deteriorating, and the children were not attending daycare. Id. The parents continued to fight and faced substantial marital problems and financial hardships. Id. The Department removed the children from the home and sued for temporary conservatorship. Id. The trial court approved a Family Service Plan outlining the requirements the parents had to satisfy to avoid termination of their rights. Id. at 68-69. Primarily because the parents failed to comply with the Plan, the Department amended its petition to seek termination. Id. at 69.
The trial court terminated the parents’ rights. Id. at 70. A divided court of appeals reversed after determining that the charge permitted the jury to find that the parents’ rights should be terminated without finding that termination would be in the children’s best interest. J.F.C., 96 S.W.3d at 260. In this Court, the parents argued, among other things, that the charge failed to require that the same ten jurors agree on the specific grounds for termination. Id. at 277. Because the question included more than one course of parental conduct justifying termination, they argued that their rights may have been terminated even though fewer than ten jurors agreed on the basis for termination. Id.
We held that even assuming the submission was improper, any error was harmless, because the Department had conclusively proved that the parents rights should be terminated under subsection O:
[*244] It is undisputed that both parents failed to comply with numerous, material provisions of court orders that specifically required their compliance to avoid restriction or termination of their parental rights.
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The evidence establishes as a matter of law that the parents failed to comply with the court’s orders specifying the actions the parents had to take for the [Department] to return the children to the parents. The record also conclusively establishes that the children were removed from their parents under Chapter 262 of the Family Code, and it is undisputed that they were in the [Department’s] custody for more than nine months after their removal. Accordingly, the parental conduct described in subsection 161.001(1)(O) of the Family Code was established as a matter of law. Any error in failing to submit a specific instruction on juror agreement regarding parental conduct was thus harmless.
Id. at 277-79. We reversed the court of appeals’ judgment and rendered judgment terminating the parents’ rights. Id. at 285.
At least one appellate court has interpreted subsection O in a similar fashion, holding that termination was warranted upon proof of “immediate danger to the physical health or safety of the child” — the emergency removal standard under chapter 262. In re M.L.J., No. 02-07-0178-CV, 2008 WL 1932076, at *5, 2008 Tex. App. LEXIS 3218, at *14-15 (Tex.App.-Fort Worth May 1, 2008, pet. denied) (mem.op.); see also Tex. Fam.Code §§ 262.101-.102, .104(a)(1)-(2). In the parents argued — as M.R. does here— that subsection O was inapplicable because their child was not removed for actual abuse or neglect, but only because of the risk of abuse or neglect. The court of appeals rejected this contention. See M.L.J., 2008 WL 1932076, at *5-6, 2008 Tex.App. LEXIS 3218, at *14-18. The Department’s investigator testified that the child was removed from the parents, who were both intellectually disabled, not just because of the parents’ “lack of skills” but also because they refused to seek help caring for their child. Id. at *5-6, 2008 Tex.App. LEXIS 3218, at *16. A psychologist corroborated his testimony, stating that the mother had reported that the father had once punched her and once shook one of the children. Id. at *6, 2008 Tex.App. LEXIS 3218, at *17. The psychologist also noted that the mother had difficulty accepting that she needed help caring for her children, and that a small child faced a high degree of risk if left in the parents’ care. Id. at *6, 2008 Tex.App. LEXIS 3218, at *17-18.
The court of appeals held that the investigator’s testimony “ “would lead a person of ordinary prudence and caution to believe that there is an immediate danger to the physical health or safety of [the child].’ ” Id. at *6, 2008 Tex.App. LEXIS 3218, at *18 (quoting Tex. Fam.Code § 262.104(a)(1)-(2)). The court concluded that the evidence supported termination under subsection O. Id.; see also In re D.R.J., 395 S.W.3d 316, 324 (Tex.App.Fort Worth Feb. 7, 2013, no pet.) (Gardner, J., concurring) (“This court has previously held that evidence was sufficient to establish removal for ‘abuse or neglect’ based upon a CPS investigator’s personal knowledge of facts that would lead a person of ordinary prudence to believe that there is ‘an immediate danger to the physical health or safety of the child’ as required for removal without a court order under family code section 262.104(a)(1), (2).”) (citing In re M.L.J.).
Conversely, other courts have held that removal due to risk of abuse or neglect[*245] does not satisfy O’s requirements. See, e.g., In re C.B., 376 S.W.3d 244, 252 (Tex.App.-Amarillo 2012, no pet.); Mann v. Dep’t of Family and Protective Servs., No. 01-08-01004-CV, 2009 WL 2961396, at *7-8, 2009 Tex.App. LEXIS 7326, at *20-21 (Tex.App.-Houston [1st Dist.] Sept. 17, 2009, no pet.) (mem.op.); In re S.A.P., 169 S.W.3d 685, 706-07 (Tex.App.-Waco 2005, no pet.) (holding that father’s rights could not be terminated under subsection O because child was removed due only to risk of abuse based on parents’ prior history).
In C.B., the court of appeals considered a case involving a mother who “admitted to recent and chronic methamphetamine use” and who was involved in, and exposed C.B. to, an abusive relationship with her boyfriend, also a methamphetamine user who kept the drug in a bedside cabinet in their shared home. C.B., 376 S.W.3d at 251. The boyfriend had threatened the mother’s life and repeatedly abused her in C.B.’s presence. Id. at 251-52. Nonetheless, the court held that termination under subsection O was not proper because although “[t]he affidavit portrays a volatile home environment and behavior by the mother and her paramour capable of resulting in abuse or neglect of a two-year-old child, ... § 161.001(1)(O) requires actual occurrence of abuse or neglect to justify termination of parental rights.” Id. at 252. Even applying the definitions of abuse and neglect in a related chapter, the court concluded that subsection O’s standard had not been satisfied. Id. at 250. “Abuse” under chapter 261 includes a parent’s current use of a controlled substance, [4] yet the court found no evidence that the mother’s methamphetamine use caused physical, mental, or emotional harm to C.B., a statutory requirement. Id. Nor had C.B. been the victim of neglect: “[A] pattern of violence directed toward the mother by her paramour would carry some risk that a two-year-old child in the home may suffer harm, but this record does not support a conclusion that C.B. was subjected to ‘a substantial risk of immediate harm.’ ” Id. (quoting Tex. Fam.Code § 261.001(4)(B)(i)). The court held that the trial court’s temporary orders were not relevant, because while they justified initial and continued removal of C.B., they contained “no findings that C.B. was actually abused or neglected.” Id. at 250-51.
In Mann, the Department removed a days-old baby from his mother due to a risk of physical abuse, based on the mother’s abuse of a sibling. Mann, 2009 WL 2961396, at *1, 2009 Tex.App. LEXIS 7326, at *1-2. The mother failed to complete the necessary court-ordered services, and the trial court terminated her rights under subsection O. Id. at *1-4, 2009 TexApp. LEXIS 7326, at *3-11. The court of appeals reversed, holding that there was no evidence that the child had actually been abused or neglected. Id. at *6, 2009 Tex.App. LEXIS 7326, at *16-17. Risk was not enough; the mother’s abusive conduct toward a sibling “do[es] not provide evidence that [the mother] abused or neglected [the removed child].” Id. at *7, 2009 TexApp. LEXIS 7326, at *20. Thus, the court held that the evidence was legally insufficient to support termination under subsection O. Id. at *7-8, 2008 Tex.App. LEXIS 3218, at *20-21.
In this case, the same court of appeals applied Mann to reach the same conclusion. 390 S.W.3d at 27 (holding that “M.R.’s abuse of Y.C. cannot be considered evidence that M.R. abused or neglected E.C.R. under section 161.001(1)(O)”). The court disregarded the trial court’s temporary orders finding “ ‘danger to [E.C.R.’s] physical health or safety’ ” and “ ‘a sub[*246] stantial risk of a continuing danger if the child is returned home,’ ” because they were based on the risk of abuse, rather than “specific allegations of neglect or abuse” of E.C.R. Id. at 27-29.
We agree that subsection 0 requires proof of abuse or neglect, [5] but we disagree that those terms can never be read to include risk. We consider their use and meaning in context of the Family Code removal provisions and the Legislature’s definitions of “abuse” and “neglect” in related chapters.
The preceding chapter, titled “Investigation of Report of Child Abuse or Neglect,” requires that “abuse” and “neglect” be reported to the authorities, and the failure to do so carries criminal penalties. Tex. Fam. Code §§ 261.101(a), .103(a), .109. The terms are defined broadly and nonexclu-sively, [6] but only “[i]n this chapter.” Id. § 261.001, (1), (4). Both definitions give examples of abusive or neglectful conduct, and both definitions explicitly include risk: abuse includes not just actual physical injury, but a “genuine threat of substantial harm from physical injury”; neglect includes placing a child in or failing to remove a child from a situation that requires actions or judgment beyond his capabilities and that results in “a substantial risk of immediate harm to the child” or a situation in which the child would be exposed to “a substantial risk of sexual conduct harmful to the child.” Id. § 261.001(1)(C), (4)(B)(i), (4)(B)(iv). Both definitions also include language that permits the consideration of harm to another child in determining whether abuse or neglect has occurred. See, e.g., id. § 261.001(1)(C) (“genuine threat of substantial harm”), (4)(B)(v) (“neglect” includes exposing a child to situations in which another child faces certain sexual crimes, like abuse and trafficking).
Once the Department receives a report of abuse or neglect, it must promptly and thoroughly investigate. Id. § 261.301(a). If the Department believes that the child’s immediate removal is necessary to avoid[*247] further abuse or neglect, it must file a petition or take other action under chapter 262 for the child’s temporary care and protection. Id. § 261.302(d).
Chapter 262, titled “Procedures in Suit by Governmental Entity to Protect Health and Safety of Child,” details the circumstances under which a governmental entity may file a suit affecting the parent-child relationship or take possession of a child without a court order. Id. § 262.001(a). The statute provides that “[i]n determining the reasonable efforts that are required to be made with respect to preventing or eliminating the need to remove a child from the child’s home or to make it possible to return a child to the child’s home, the child’s health and safety is the paramount concern.” Id. § 262.001(b). The Department, a law enforcement officer, or a juvenile probation officer may take possession of a child without a temporary restraining order if the child faces an immediate danger to his physical health or safety; has been a victim of sexual abuse; is in the possession of someone who is using a controlled substance, if it poses an immediate danger to the child’s physical health or safety; or is in the possession of someone who has permitted him to remain on premises used for methamphetamine manufacture. Id. § 262.104(a)-(b). If the Department petitions for possession of a child without prior notice and a hearing, it must submit an affidavit stating, among other things, “facts sufficient to satisfy a person of ordinary prudence and caution” that the child faces an immediate danger to his health or safety, or that the child has been a victim of neglect or sexual abuse, and that continuation in the home would be contrary to the child’s welfare. Id. § 262.101. The trial court may issue a temporary restraining order only if it finds that one of those conditions has been satisfied.
Within fourteen days after the Department has taken possession of the child, the trial court must hold a full adversary hearing. Id. § 262.201(a). Following the hearing, the trial court must order the child returned to his parent unless the court finds sufficient evidence to satisfy a person of ordinary prudence and caution that: there was a danger to the child’s physical health or safety that was caused by an act or failure to act of the person entitled to possession, and for the child to remain in the home is contrary to his welfare; the urgent need for protection required the immediate removal of the child and reasonable efforts, consistent with the circumstances and providing for the child’s safety, were made to eliminate or prevent the child’s removal; and reasonable efforts have been made to enable the child to return home, but there is a substantial risk of a continuing danger if the child is returned home. Id. § 262.201(b). Continued removal is warranted only if the child faces a continuing danger to his physical health or safety. Id. § 262.201(b)-(c).
The standard used repeatedly throughout chapter 262 is “danger to the physical health or safety of the child.” That phrase is also centered on risk, rather than just a history of actual abuse or neglect: the Legislature has defined it to include “exposure of the child to loss or injury that jeopardizes the physical health or safety of the child without regard to whether there has been an actual prior injury to the child.” Id. § 101.009; see also id. § 101.001(a) (“Definitions in this subchap-ter apply to this title.”). In determining whether the child faces a continuing danger to his physical health or safety, at each stage of the proceedings the court may consider whether the child’s household includes a person who has: “(1) abused or neglected another child in a manner that caused serious injury to or the death of the[*248] other child; or (2) sexually abused another child.” Id. §§ 262.102(b) (temporary restraining order), 262.107(b) (initial hearing), 262.201(d) (full adversary hearing).
Although chapter 261’s “abuse” and “neglect” definitions do not govern in chapter 262, they surely inform the terms’ meanings. See, e.g., Brown v. Darden, 121 Tex. 495, 50 S.W.2d 261, 263 (1932) (“Whenever a legislature has used a word in a statute in one sense and with one meaning, and subsequently uses the same word in legislating on the same subject-matter, it will be understood as using it in the same sense, unless there be something in the context or the nature of things to indicate that it intended a different meaning thereby.”). So while subsection O requires removal under chapter 262 for abuse or neglect, those words are used broadly. Consistent with chapter 262’s removal standards, “abuse or neglect of the child” necessarily includes the risks or threats of the environment in which the child is placed. Part of that calculus includes the harm suffered or the danger faced by other children under the parent’s care. If a parent has neglected, sexually abused, or otherwise endangered her child’s physical health or safety, such that initial and continued removal are appropriate, the child has been “remov[ed] from the parent under Chapter 262 for the abuse or neglect of the child.” See Tex. Fam.Code §§ 161.001(1)(O), 262.101, .102, .104, .107, .201. [7]
Here, the Department’s evidence in support of removal included an affidavit showing that the department received a referral of physical abuse of Y.C. A witness had seen M.R. punching Y.C. and dragging her by her hair. Y.C. had sustained injuries. M.R. denied the abuse, but she was arrested and charged with intentional bodily injury to a child. She had been involved in a prior CPS case involving physical abuse of her older son, who was in the foster parents’ permanent conservatorship. She left E.C.R. with her boyfriend, who was not E.C.R.’s father, had an extensive criminal history, and had physically abused her. She was incarcerated and unable to care for E.C.R. This affidavit, even if not evidence for all purposes, shows what the trial court relied on in determining whether removal was justified. That court found sufficient evidence to satisfy a person of ordinary prudence and caution that E.C.R. faced an immediate danger to his physical health or safety, that the urgent need to protect him required his immediate removal, and that he faced a substantial risk of a continuing danger if he were returned home — findings unchallenged by M.R. [8] This evidence[*249] and these findings establish that E.C.R. was removed from M.R. under chapter 262 for abuse or neglect. See, e.g., In re J.S.G., No. 14-08-00754-CV, 2009 WL 1311986, at *6-7, 2009 Tex.App. LEXIS 3224, at *18-20 (Tex.App.-Houston [14th Dist.] May 7, 2009, no pet.) (mem.op.) (relying on caseworker’s affidavit in support of the Department’s removal request, as well as trial court’s temporary orders concluding that the children faced a danger to their physical health or safety and a substantial risk of a continuing danger if returned home, to conclude that the evidence established that the children were removed “as a result of neglect specific to them by” the mother); see also D.F. v. Tex. Dep’t of Family & Protective Servs., 393 S.W.3d 821, 830-31 (Tex.App.-El Paso 2012, no pet.) (noting that trial court’s finding of immediate danger to child’s physical health or safety or that they were neglected or abused supported finding of neglect); In re S.N., 287 S.W.3d 183, 190 (Tex.App.-Houston [14th Dist.] 2009, no pet.) (holding that affidavit, family service plan, and temporary orders showing danger to physical health or safety and “ ‘substantial risk of continuing danger’ ” supported finding that children were removed under chapter 262 for neglect); In re A.A.A., 265 S.W.3d 507, 516 (Tex.App.Houston [1st Dist.] 2008, pet. denied) (considering affidavit in support of removal and trial court’s temporary orders finding “ ‘continuing danger to the physical health or safety of the child if returned to the parent’ ” as evidence that child was removed because of neglect).
M.R. does not dispute that she “failed to comply -with numerous, material provisions of court orders that specifically required ... compliance to avoid restriction or termination of parental rights.” J.F.C., 96 S.W.3d at 277. As in J.F.C., the record conclusively establishes that E.C.R. was removed from M.R. under Chapter 262 of the Family Code for abuse or neglect, and it is undisputed that he was in the Department’s custody for more than nine months after his removal. The parental conduct described in subsection 161.001(1)(O) of the Family Code was thus established as a matter of law.
III. A reasonable factfinder could have formed a firm belief or conviction that termination was in E.C.R.’s best interest.
M.R. also challenges the sufficiency of the evidence supporting the best interest finding. In reviewing this finding, we consider, among other evidence, the Holley [9] factors. In re E.N.C., 384 S.W.3d 796, 807 (Tex.2012). Many of the reasons supporting termination under subsection O also support the trial court’s best interest finding. See In re C.H., 89 S.W.3d 17, 28 (Tex.2002) (holding that same evidence may be probative of both section 161.001(1) grounds and best interest). M.R. pleaded guilty to causing injury to a child, a third[*250] degree felony. She twice attempted suicide while incarcerated on that charge, and there was evidence that she was mentally unstable. She no longer has custody of any of her four children. Her oldest was taken into Department custody several years earlier after a referral of physical abuse, and the trial court terminated her parental rights. E.C.R. lives in the same foster home with M.R.’s youngest child, a baby who was born after E.C.R. was taken into custody. M.R. has a history of homelessness, and at the time of the hearing, she had not lived in a home for six months. She has not been employed at any time since E.C.R. was taken into custody, jeopardizing her parental rights and violating the conditions of her community supervision. Although she told the child advocate she was unable to work due to pregnancy, she was unable to provide documentation substantiating that claim, nor did she explain her inability to work at all during the fourteen months the case was pending. When E.C.R. came into care, he was behind on his immunizations. He has done “very well” in foster care, and his foster parents are meeting his physical and emotional needs. The Department’s long term goal for E.C.R. is unrelated adoption, although there was no evidence that his foster family would, or would not, adopt him. C.H., 89 S.W.3d at 28 (“Evidence about placement plans and adoption are, of course, relevant to best interest.”). But “the lack of evidence about definitive plans for permanent placement and adoption cannot be the dispositive factor.” Id. Rather, we examine the entire record to decide best interest, “even if the agency is unable to identify with precision the child’s future home environment.” Id. We conclude that there is evidence from which a fact-finder could have formed a firm belief or conviction that termination of M.R.’s parental rights was in E.C.R.’s best interest.
M.R. also challenged the factual sufficiency of the evidence supporting the best interest finding, a question that the court of appeals must decide. See Tex. Const. art. V, § 6(a). We remand to that court for consideration of the issue.
IV. Conclusion
We reverse in part the court of appeals’ judgment and remand to that court for further proceedings. Tex.R.App. P. 60.2(d).
. Lassiter v. Dep’t of Soc. Servs., 452 U.S. 18, 27, 101 S.Ct. 2153, 68 L.Ed.2d 640 (1981); see In re E.R., 385 S.W.3d 552, 563 (Tex.2012) ("Parental rights are 'far more precious than any property right,' and when the State initiates a termination proceeding, ‘it seeks not merely to infringe that fundamental liberty interest, but to end it.’ ”) (quoting Santosky v. Kramer, 455 U.S. 745, 758-59, 102 S.Ct. 1388, 71 L.Ed.2d 599 (1982)); see also Holick v. Smith, 685 S.W.2d 18, 21 (Tex.1985) (noting that "involuntary termination statutes are strictly construed in favor of the parent").
. See also Tex. Fam.Code § 153.001(a)(2) ("The public policy of this state is to ... provide a safe, stable, and nonviolent environment for the child.”).
. The court of appeals refused to consider the Department's cross-points asserting alternative bases for termination. 390 S.W.3d at 29-30 (holding that "a parental rights termination order can be upheld only on grounds both pleaded by [the Department] and found by the trial court”) (quoting Vasquez v. Texas Dep't of Protective & Regulatory Servs., 190 S.W.3d 189, 194 (Tex.App.-Houston [1st Dist.] 2005, pet. denied)). But see id. at 47 (Keyes, J., dissenting) (stating that "predicate acts under section 161.001(1) raised by [the Department] and supported by the evidence, but not expressly found by the trial court” should be considered by appellate court). The Department contends this was error. Because we hold that the Department conclusively proved grounds for termination under subsection O, we do not reach this issue.
. See Tex. Fam.Code § 261.001(1)(I).
. See, e.g., In re A.A.A., 265 S.W.3d 507, 515 (Tex.App.-Houston [1st Dist.] 2008, pet. denied) (holding that subsection O requires proof of abuse or neglect, which should be determined on a case-by-case basis); see also D.F. v. Tex. Dep't of Family & Protective Servs., 393 S.W.3d 821, 828 (Tex.App.-El Paso 2012, no pet.) (concluding that subsection O requires proof of abuse or neglect); In re M.N., No. 11-10-00129-CV, 2011 WL 917837, at *3, 2011 Tex.App. LEXIS 1924, at *9 (Tex.App.-Eastland Mar. 17, 2011, no pet.)(mem.op.) (same); In re S.N., 287 S.W.3d 183, 190 (Tex.App.-Houston [14th Dist.] 2009, no pet.) (same); In re M.L.J., No. 2-07-178-CV, 2008 WL 1932076, at *5, 2008 Tex.App. LEXIS 3218, at *14 (Tex.App.-Fort Worth May 1, 2008, pet denied) (mem.op.) (same); In re S.A.P., 169 S.W.3d 685, 705-06 (Tex. App.-Waco 2005, no pet.) (same); In re M.B., No. 07-04-0334-CV, 2004 WL 2867544, at *2, 2004 Tex.App. LEXIS 11209, at *7 (Tex. App.-Amarillo Dec. 14, 2004, no pet.)(mem. op.) (same).
. See Tex Gov’t Code § 311.005(13) (“'Includes' and 'including' are terms of enlargement and not of limitation or exclusive enumeration, and use of the terms does not create a presumption that components not expressed are excluded."); Tex. West Oaks Hosp., LP v. Williams, 371 S.W.3d 171, 179 (Tex.2012) (holding that Legislature’s use of the term "including” meant that statutory definition was nonexclusive); see also Samantar v. Yousuf, 560 U.S. 305, 130 S.Ct. 2278, 2287, 176 L.Ed.2d 1047 (2010) (observing that "use of the word 'include' can signal that the list that follows is meant to be illustrative rather than exhaustive”) (citing 2A N. Singer & J. Singer, Sutherland Statutory Construction § 47.7, p. 305) (7th ed.2007) ("[T]he word 'includes' is usually a term of enlargement, and not of limitation” (some internal quotation marks omitted)); Fed. Land Bank v. Bismarck Lumber Co., 314 U.S. 95, 99-100, 62 S.Ct. 1, 86 L.Ed. 65 (1941) (holding that "the term 'including' is not one of all-embracing definition, but connotes simply an illustrative application of the general principle”).
. Cf. Tex. Fam.Code § 161.001(1)(E) (authorizing termination if parent engages in conduct that "endangers the physical or emotional well-being of the child ”) (emphasis added); In re J.O.A., 283 S.W.3d 336, 345 (Tex.2009) (holding that "the endangering conduct may include the parent’s actions before the child's birth, while the parent had custody of older children, including evidence of drug usage”); Tex. Dep't of Human Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex.1987) (holding that conduct that “ 'endangers ... the child' " did not require that actions "be directed at the child or that the child actually suffers injury”) (quoting former Tex. Fam.Code § 15.02(1)(E)).
. See, e.g., Dancy v. Daggett, 815 S.W.2d 548, 549 (Tex.1991) (holding that mandamus relief was appropriate because trial court's temporary orders were not subject to interlocutory appeal); In re Steed, No. 03-08-00235-CV, 2008 WL 2132014, at *1, 2008 Tex.App. LEXIS 3652, at *2 n. 3 (Tex.App.-Austin May 22, 2008, orig. proceeding) ("Because temporary orders in a suit affecting a parent-child relationship are not subject to interlocutory appeal under the family code, mandamus review is appropriate.”), mand. denied, 255 S.W.3d 613, 615 (Tex.2008, orig. proceeding) ("[W]e are not inclined to disturb the court of appeals' decision.”). But see Tex. Fam.Code § 262.112(b) (“In any proceeding in which an[*249] expedited hearing is held under Subsection (a), the department, parent, guardian, or other party to the proceeding is entitled to an expedited appeal on a ruling by a court that the child may not be removed from the child’s home.”) (emphasis added).
. See Holley v. Adams, 544 S.W.2d 367, 371-72 (Tex.1976). These factors include: (1) the child’s desires; (2) the child’s present and future emotional and physical needs; (3) any present or future emotional and physical danger to the child; (4) the parental abilities of the individuals seeking custody; (5) the programs available to assist the individuals seeking custody to promote the child’s best interest; (6) the plans for the child by the individuals or agency seeking custody; (7) the stability of the home or proposed placement; (8) the parent’s acts or omissions which may indicate that the existing parent-child relationship is improper; and(9) any excuse for the parent's acts or omissions. Id.