in the Interest of Z.M.M., a Child, 577 S.W.3d 541 (Tex. 2019). · Go Syfert
in the Interest of Z.M.M., a Child, 577 S.W.3d 541 (Tex. 2019). Cases Citing This Book View Copy Cite
90 citation events (90 in the last 25 years) across 4 distinct courts.
Strongest positive: B. C. and J. G. F. v. Texas Department of Family and Protective Services (texapp, 2025-04-11)
Treatment trajectory · 2019 → 2026 · click a year to view as-of
2019 2022 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (quoted) B. C. and J. G. F. v. Texas Department of Family and Protective Services
Tex. App. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
courts must broadly construe issues to reach all core and substantive questions such that the merits of an appeal are addressed when reasonably possible to provide the party with a meaningful appeal.
discussed Cited as authority (quoted) In the Interest of M.N.M., a Child v. the State of Texas
Tex. App. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
courts must broadly construe issues to reach all core and substantive questions such that the merits of an appeal are addressed when reasonably possible to provide the party with a meaningful appeal.
discussed Cited as authority (quoted) In the Interest of J.R and J.R., Children v. the State of Texas
Tex. App. · 2024 · quote attribution · 1 verbatim quote · confidence low
courts must broadly construe issues to reach all core and substantive questions such that the merits of an appeal are addressed when reasonable possible to provide the party with a meaningful appeal.
discussed Cited as authority (quoted) in the Interest of F. L. B., A. C. B., J. G. B., E. B. M., Children (2×) also: Cited "see"
Tex. App. · 2019 · signal: see · quote attribution · 1 verbatim quote · confidence high
courts must broadly construe issues to reach all core and substantive questions such that the merits of an appeal are addressed when reasonably possible to provide the party with a meaningful appeal.
cited Cited as authority (rule) In the Interest of A.M., a Child v. the State of Texas
txctapp6 · 2026 · confidence medium
Termination on grounds D or E “has consequences for termination of parental rights as to children in a future proceeding.” In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam); see TEX.
cited Cited as authority (rule) In the Interest of A.C. and E.C., Jr., Children v. the State of Texas
txctapp6 · 2026 · confidence medium
Termination on grounds D or E “has consequences for termination of parental rights as to children in a future proceeding.” In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam); see TEX.
discussed Cited as authority (rule) In the Interest of S.J., a Child v. the State of Texas
txctapp6 · 2026 · confidence medium
In re R.R.A., 687 S.W.3d at 277.5 Termination on grounds D or E “has consequences for termination of parental rights as to children in a future proceeding.” In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam); see TEX.
cited Cited as authority (rule) In the Interest of N. P. G. a Child v. Department of Family and Protective Services
txctapp1 · 2026 · confidence medium
See id.; In re Z.M.M., 577 S.W.3d 541, 542-43 (Tex. 2019) (per curiam).
discussed Cited as authority (rule) In the Interest of G.P.-J.R. and C.S.-L.R., Children v. the State of Texas
Tex. App. · 2025 · confidence medium
Termination on predicate grounds D or E thus “has consequences for termination of parental rights as to children in a future proceeding.” In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam); In re N.G., 577 S.W.3d at 235 .
discussed Cited as authority (rule) In the Interest of C.C., a Child v. the State of Texas
Tex. App. · 2025 · confidence medium
In re R.R.A., 687 S.W.3d at 276–77.19 Termination on grounds D or E “has consequences for termination of parental rights as to children in a future proceeding.” In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam); see TEX.
discussed Cited as authority (rule) In the Interest of B.M.P.J., a Child v. the State of Texas (2×) also: Cited "see"
Tex. App. · 2024 · confidence medium
We focus on the finding that Mother failed to comply with the court-ordered family service plan.4 4 When termination is based on multiple statutory grounds, we will generally affirm if any one of those grounds is supported by legally and factually sufficient evidence In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam) (stating that “only one ground is required to terminate parental rights”).
discussed Cited as authority (rule) In the Interest of J.S.H., a Child v. the State of Texas
Tex. App. · 2024 · confidence medium
Accordingly, “due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (per curiam); In re N.G., 577 S.W.3d at 237 .
discussed Cited as authority (rule) In the Interest of J.S.H., a Child v. the State of Texas
Tex. App. · 2024 · confidence medium
Accordingly, “due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (per curiam); In re N.G., 577 S.W.3d at 237 .
cited Cited as authority (rule) In the Interest of C.W., a Child v. the State of Texas
Tex. App. · 2024 · confidence medium
N.G., 577 S.W.3d at 235 ; see also In re C.W., 586 S.W.3d 405 , 407 (Tex. 2019) (relying on N.G.); In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (relying on N.G.).
cited Cited as authority (rule) In the Interest of A.N.C., a Child v. the State of Texas
Tex. App. · 2023 · confidence medium
CODE ANN. § 161.001(b)(1)(O); In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019).
discussed Cited as authority (rule) In the Interest of S.C.M., a Child v. Department of Family and Protective Services (2×)
Tex. App. · 2023 · confidence medium
CODE § 161.001(b) (requiring only one predicate ground to support termination); In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam) (stating that “only one ground is required to terminate parental rights”).
discussed Cited as authority (rule) In the Interest of J.M.R., a Child v. the State of Texas
Tex. App. · 2023 · confidence medium
But “due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019).
discussed Cited as authority (rule) in the Interest of C.A.L., a Child
Tex. App. · 2022 · confidence medium
Therefore, “due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” Id. (quoting In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (per curiam)).
discussed Cited as authority (rule) in the Interest of A.C., a Child
Tex. App. · 2022 · confidence medium
Therefore, “due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” Id. (quoting In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (per curiam)).2 Under section 161.001(b)(1)(D), parental rights may be terminated if clear and convincing evidence supports a finding that the parent “knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endanger the physical or emotional well-being of the child.” TEX.
cited Cited as authority (rule) in the Interest of M.U.A.T.
Tex. App. · 2022 · confidence medium
CODE ANN. § 161.001(d); In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019).
discussed Cited as authority (rule) in the Interest of E.P., a Child
Tex. App. · 2022 · confidence medium
See id. § 161.001(b) (requiring only one predicate ground to support termination); In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam) (stating that "only one ground is required to terminate parental rights").
discussed Cited as authority (rule) in the Interest of A.M.R., a Child
Tex. App. · 2022 · confidence medium
See id. § 161.001(b) (requiring only one predicate ground to support termination); In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam) (stating that "only one ground is required to terminate parental rights").
discussed Cited as authority (rule) in the Interest of S.R. & N.R., Children
Tex. App. · 2022 · confidence medium
Therefore, “due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019). –5– S.W.3d 365, 370 (Tex. App.—Dallas 2013, pets. denied).
discussed Cited as authority (rule) in the Interest of A.P., a Child
Tex. App. · 2022 · confidence medium
See id. § 161.001(b) (requiring only one predicate ground to support termination); In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam) (stating that "only one ground is required to terminate parental rights").
discussed Cited as authority (rule) in the Interest of A.W., a Child (2×) also: Cited "see"
Tex. App. · 2021 · confidence medium
In re N.G., 577 S.W.3d 230, 235, 237 (Tex. 2019) (per curiam); see also In re C.W., 586 S.W.3d 405 , 407 (Tex. 2019) (per curiam); In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (per curiam). 30 Under Subsection (E), DFPS had to prove that Father engaged in conduct or knowingly placed Amanda with persons who engaged in conduct that endangered her physical or emotional well-being.
discussed Cited as authority (rule) in the Interest of C.N.L., P.A.L., D.J.L., D.D.L., B.M.L., J.J.L., and J.J.L., Children
Tex. App. · 2021 · confidence medium
In re N.G., 577 S.W.3d at 234, 237 (holding that “due process and due course of law requirements mandate that an appellate court detail its analysis for an appeal of termination of parental rights” on endangerment grounds because an endangerment finding “becomes a basis to terminate that parent’s rights to other children” under § 161.001(b)(1)(M)); see In re L.G., 596 S.W.3d 778 , 781 (Tex. 2020) (per curiam); In re C.W., 586 S.W.3d 405 , 507 (Tex. 2019) (per curiam); In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam); see also TEX.
discussed Cited as authority (rule) in the Interest of E.R., P.R., Jr., S.R., and S.R., Children
Tex. App. · 2021 · confidence medium
In re L.G., 596 S.W.3d 778 , 781 (Tex. 2020) (concluding the court of appeals erred in failing to detail its analysis 8 of the challenged findings under subsections (D) and (E) after affirming termination on another subsection) (citing In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019)).
discussed Cited as authority (rule) in the Interest of M.J., a Child
Tex. App. · 2020 · confidence medium
In re N.G., 577 S.W.3d at 234, 237 (holding that “due process and due course of law requirements mandate that an appellate court detail its analysis for an appeal of termination of parental rights” on endangerment grounds because an endangerment finding “becomes a basis to terminate that parent’s rights to other children” under part (M)); see In re L.G., 596 S.W.3d 778 , 781 (Tex. 2020) (per curiam); In re C.W., 586 S.W.3d 405 , 507 (Tex. 2019) (per curiam); In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam).
cited Cited as authority (rule) in the Interest of S.R.L., a Child
Tex. App. · 2020 · confidence medium
In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (per curiam); In re C.V.L., 591 S.W.3d at 748–49.
cited Cited as authority (rule) in Re D.C., J.C. III, J.C., and J.C.
Tex. App. · 2020 · confidence medium
See In re N.G., 577 S.W.3d at 235–37; see also In re C.W., 586 S.W.3d 405 , 407 (Tex. 2019) (per curiam); In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (per curiam).
discussed Cited as authority (rule) in the Interest of C.V.L., a Child
Tex. App. · 2019 · confidence medium
Therefore, “due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (per curiam).
discussed Cited as authority (rule) in the Interest of A.D.G., a Child
Tex. App. · 2019 · confidence medium
But “due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019). -2- 04-19-00413-CV B.
discussed Cited as authority (rule) J. G. v. Texas Department of Family and Protective Services
Tex. App. · 2019 · confidence medium
See id. at 235, 237 ; In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (per curiam). 8 produced by the conduct of the parent[] bears on the determination of whether the child’s surroundings threaten his well-being.” In re M.D.M., 579 S.W.3d 744, 764 (Tex. App.— Houston [1st Dist.] 2019, no pet.) (quoting Jordan v. Dossey, 325 S.W.3d 700, 721 (Tex. App.— Houston [1st Dist.] 2010, pet. denied)).
discussed Cited as authority (rule) in the Interest of Z.J. and D.J., Children
Tex. App. · 2019 · confidence medium
See id. § 161.001(b) (requiring only one predicate ground to support termination); In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam) (stating that “only one ground is required to terminate parental rights”); In re A.V., 113 S.W.3d 355, 362 (Tex. 2003) (interpreting Section 161.001(b) as requiring only one predicate ground); see also Toliver v. Tex. Dep’t of Family & Protective Servs., 217 S.W.3d 85 , 102–03 (Tex. App.—Houston [1st Dist.] 2006, no pet.) (holding that failure to challenge all of the trial court’s predicate-ground findings resulted in waiver). 23 B.
discussed Cited as authority (rule) in the Interest of L.J.G., S.A.M., and A.C.F.
Tex. App. · 2019 · confidence medium
But “due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019).
discussed Cited as authority (rule) in the Interest of K.B., a Child
Tex. App. · 2019 · confidence medium
Therefore, “due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (per curiam).
discussed Cited as authority (rule) in the Interest of E.J.C, Jr., S.R.C., E.D.C., Children (2×) also: Cited "see"
Tex. App. · 2019 · confidence medium
The trial court was the “sole judge[] of the credibility of the witnesses and the weight to give their ii “[D]ue process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal.” In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (emphasis added).
cited Cited "see" In the Interest of A.A. Jr. and K.A., Children v. the State of Texas
Tex. App. · 2024 · signal: see · confidence high
See In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam) (stating that "only one ground is required to terminate parental rights").
discussed Cited "see" In the Interest of Z.R.E.B., a Child v. the State of Texas
Tex. App. · 2024 · signal: see · confidence high
See In re Z.M.M., 577 S.W.3d 541 , 542–43 (Tex. 2019) (requiring appellate court to review a trial court’s decision under Section 161.001(d) when addressing the sufficiency of the evidence to support a finding under Section 161.001(b)(1)(O)); In re B.J.F., No. 01-23-00522- CV, 2024 WL 117174 , at *21 (Tex. App.—Houston [1st Dist.] Jan. 11, 2024, pet. filed) (mem. op.) (addressing the merits of the appellant’s Section 161.001(d) claim, even though she did not plead it or raise it at trial).
cited Cited "see" In the Interest of D.M. and D.M v. the State of Texas
Tex. App. · 2024 · signal: see · confidence high
See In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019); In re A.V., 113 S.W.3d 355, 362 (Tex. 2003).
discussed Cited "see" In the Interest of S.M. and J.M., Children v. the State of Texas
Tex. App. · 2023 · signal: see · confidence high
In re N.G., 577 S.W.3d 230, 235, 237 (Tex. 2019); see also In re C.W., 586 S.W.3d 405 , 407 (Tex. 2019) (relying on N.G. and holding same); see In re Z.M.M., 577 S.W.3d 541, 543 (Tex. 2019) (relying on N.G. to hold that the court of appeals erred by not addressing the father’s sufficiency challenge to the trial court’s Subsection (D) finding).
discussed Cited "see" In the Interest of M.G., a Child v. the State of Texas (2×) also: Cited "see, e.g."
Tex. App. · 2023 · signal: see · confidence high
See In re Z.M.M., 577 S.W.3d 541 , 542–43 (Tex. 2019) (holding that although father did not explicitly raise a Section 161.001(d) argument in the court of appeals, his arguments should have alerted the court that he was urging a Section 161.001(d) defense).
cited Cited "see" in the Interest of A.R. Jr.
Tex. App. · 2023 · signal: see · confidence high
See In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019).
discussed Cited "see" in the Interest of A.I., a Child
Tex. App. · 2022 · signal: see · confidence high
See In re Z.M.M., 577 S.W.3d 541 , 542–43 (Tex. 2019) (instructing courts of appeals to “broadly construe issues to reach all core and substantive questions . . . when reasonably possible”).
discussed Cited "see" R. J. and A. D. M. v. Texas Department of Family and Protective Services
Tex. App. · 2022 · signal: see · confidence high
Code § 161.001(d); see In re Z.M.M., 577 S.W.3d 541 , 542–43 (Tex. 2019) (discussing affirmative defense provided in section 161.001(d)); R.S.S. v. Texas Dep’t of Fam. & Protective Servs., No. 03-22-00076-CV, 2022 Tex. App. LEXIS 4864 , at *10–11 (Tex. App.—Austin July 15, 2022, no pet. h.) (mem. op.) (explaining that “[s]ection 161.001(d) is an affirmative defense to subsection (O) that places the burden of proof on the parent” and that “the parent must satisfy this burden for each specific provision of the court order that the State claims he failed to complete”).
cited Cited "see" in the Interest of L.S., a Child
Tex. App. · 2022 · signal: see · confidence high
See In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019) (per curiam) (stating that "only one ground is required to terminate parental rights").
discussed Cited "see" R. J. and A. D. M. v. Texas Department of Family and Protective Services
Tex. App. · 2022 · signal: see · confidence high
Code § 161.001(d); see In re Z.M.M., 577 S.W.3d 541 , 542–43 (Tex. 2019) (discussing affirmative defense provided in section 161.001(d)); R.S.S. v. Texas Dep’t of Fam. & Protective Servs., 9 Mother cites In re K.C.P., 142 S.W.3d 574 (Tex. App.—Texarkana 2004, no pet.), as supporting her position that the challenged testimony was inadmissible.
cited Cited "see" in the Interest of D.P. and D.P.
Tex. App. · 2022 · signal: see · confidence high
See In re Z.M.M., 577 S.W.3d 541, 542 (Tex. 2019).
discussed Cited "see" in the Interest of L.O., A.O. III, C.O., A.O., N.O., A.O. L.W. and T.J., Children
Tex. App. · 2022 · signal: see · confidence high
See In re Z.M.M., 577 S.W.3d 541 , 542–43 (Tex. 2019) (instructing courts of appeals to “broadly construe issues to reach all core and substantive questions . . . when reasonably possible”).
discussed Cited "see" in the Interest of G.L. A/K/A A.L. A/K/A A.L.G.L., a Child
Tex. App. · 2022 · signal: see · confidence high
See In re Z.M.M., 577 S.W.3d at 542–43 (reversing and remanding to the court of appeals for reconsideration of termination grounds under § 161.001(b)(1)(O) because the court of appeals failed to recognize that Father’s argument implicitly challenged the trial court’s findings under § 161.001(d)).
Retrieving the full opinion text from the archive…
In the INTEREST OF Z.M.M., a Child
NO. 18-0734.
Texas Supreme Court.
May 17, 2019.
577 S.W.3d 541
PER CURIAM

In this parental termination case, the trial court terminated the father's parental rights under three grounds for termination specified in the Texas Family Code-section 161.001(b)(1)(D), (N), and (O). See TEX. FAM. CODE § 161.001(b)(1)(D), (N), (O). The father appealed, challenging the sufficiency of the evidence as to all three grounds, and the court of appeals affirmed the trial[*542] court's order for termination based only on section 161.001(b)(1)(O) because an appellate court need only uphold one ground for termination on appeal. 575 S.W.3d 817 , ----, 2018 WL 3129440 (Tex. App.-San Antonio 2018) (mem. op.); see also TEX. FAM. CODE § 161.001(b) ; TEX. R. APP. P. 47.1. The court of appeals also upheld the trial court's finding that termination of the father's parental rights was in the child's best interest. 575 S.W.3d at ----.

Parental rights may be terminated under section 161.001(b)(1)(D) if clear and convincing evidence supports a finding that the parent "knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endanger the physical or emotional well-being of the child." TEX. FAM. CODE § 161.001(b)(1)(D). Parental rights may be terminated under section 161.001(b)(1)(O) if clear and convincing evidence supports that the parent "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." Id. § 161.001(b)(1)(O). Under section 161.001(b)(1)(M), a court may terminate parental rights if the parent previously "had his or her parent-child relationship terminated with respect to another child based on a finding that the parent's conduct was in violation of Paragraph (D) or (E) or substantially equivalent provisions of the law of another state." Id. § 161.001(b)(1)(M). Because only one ground is required to terminate parental rights and section 161.001(b)(1)(D) has consequences for termination of parental rights as to children in a future proceeding under section 161.001(b)(1)(M), terminating parental rights under section 161.001(b)(1)(D) implicates significant due process concerns for a parent's care, custody, and control of his children. See id. § 161.001(b)(1)(D), (M) ; U.S. CONST. AMEND. XIV, § 1 ; TEX. CONST. art. I, § 19.

Further, under section 161.001(d),

A court may not order termination under Subsection (b)(1)(O) based on the failure by the parent to comply with a specific provision of a court order if a parent proves by a preponderance of evidence that:
(1) the parent was unable to comply with specific provisions of the court order; and
(2) the parent made a good faith effort to comply with the order and the failure to comply with the order is not attributable to any fault of the parent.

TEX. FAM. CODE § 161.001(d). In its order for termination, the trial court found that the father did not prove by a preponderance of evidence that he "was unable to comply with specific provisions of a court order" and that he did not prove he "made a good faith effort to comply with the order and the failure to comply with the order [was] not attributable to any fault of the parent." Id. Although the father framed the issue in the court of appeals as sufficiency of the evidence to terminate his rights under section 161.001(b)(1)(O), the father's argument consisted of reasons why he could not comply with the order, asserting that it was not his fault he was unable to comply with the order despite his good faith effort. In this Court, the father asserts that section 161.001(d) should have precluded the trial court from terminating his rights under section 161.001(b)(1)(O).

The trial court's finding that section 161.001(d) did not preclude termination under section 161.001(b)(1)(O) and the father's arguments on appeal should have alerted the court of appeals to the father's arguments under section 161.001(d). Courts must broadly construe issues to reach all core and substantive questions such that the merits of an appeal are addressed when reasonably possible to[*543] provide the party with a meaningful appeal. See Ditta v. Conte , 298 S.W.3d 187 , 189-90 (Tex. 2009) ; In re S.K.A. , 236 S.W.3d 875 , 889-90 (Tex. App.-Texarkana 2007, pet. denied) ; see also TEX. R. APP. P. 38.9. In finding that the evidence was sufficient to terminate the father's parental rights under section 161.001(b)(1)(O) due to the father's failure to comply with the order, the court of appeals should also have reviewed the trial court's decision as to section 161.001(d) based on the father's arguments that he was unable to comply with the order despite a good faith effort. The court of appeals erred in failing to address section 161.001(d) as it related to termination of the father's parental rights under section 161.001(b)(1)(O), depriving the father of a meaningful appeal of all substantive issues.

In light of our holding in In re N.G. , 577 S.W.3d 230 , 2019 WL 2147263 (Tex. 2019) (per curiam)-in which we held that due process requires an appellate court to review and detail its analysis as to termination of parental rights under section 161.001(b)(1)(D) or (E) of the Family Code when challenged on appeal-we hold that the court of appeals erred in failing to address the father's challenge as to section 161.001(b)(1)(D), upholding the order for termination based only on section 161.001(b)(1)(O). We also hold that the court of appeals erred in failing to address the merits of section 161.001(d) as it relates to termination of the father's parental rights under section 161.001(b)(1)(O). Without hearing oral argument, see TEX. R. APP. P. 59.1, we grant the father's petition and remand the case to the court of appeals for further proceedings consistent with this opinion and our opinion in In re N.G.