In Re As (2008)
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· 297 citation events
across 4 courts.
Showing the 50 strongest citers on record
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Treatment trajectory · 2008 → 2026 · click a year to view the case as of then
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in the Interest of D. D. M., J. C. M. and J. D. M., Jr. Children v. Department of Family and Protective Servi… (2019)
See id. (“While the trial court could have chosen to disbelieve this 23 testimony, we are mindful that under a factual sufficiency review we must consider all of the evidence equally.”).
“While the trial court could have chosen to disbelieve this 23 testimony, we are mindful that under a factual sufficiency review we must consider all of the evidence equally.”
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in the Interest of a Child A. A. H AKA A.H v. Department of Family and Protective Services (2020)
See A.S., 261 S.W.3d at 86 (“While unquestionably, an exercise of poor judgment, Veronica’s use of marijuana on a single occasion, standing alone, does not rise to the level of a conscious course of conduct.”).
“While unquestionably, an exercise of poor judgment, Veronica’s use of marijuana on a single occasion, standing alone, does not rise to the level of a conscious course of conduct.”
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In the Interest of F.H. and D.K.A., Children v. Department of Family and Protective Services (2026)
CODE § 151.001(e)(1); In re A.S., 261 S.W.3d at 88 (“[I]nfrequent spankings of a child that leave ‘marks’ or visible bruises 24 hours after the spanking do not constitute sufficient evidence to demonstrate that a parent has engaged in conduct that endangered a child’s physical or emotional well-being.”).
“[I]nfrequent spankings of a child that leave ‘marks’ or visible bruises 24 hours after the spanking do not constitute sufficient evidence to demonstrate that a parent has engaged in conduct that endangered a child’s physical or emotional well-being.”
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Jerry Neill Sharpe v. the State of Texas (2022)
In the charge conference, Sharpe’s attorney also requested the following language: “Infrequent spankings of a child that leave marks or visible bruises 24 hours after spanking do not constitute sufficient evidence to demonstrate that a parent engaged in conduct that endangered a child’s physical or emotional well-being.” See In re A.S., 261 S.W.3d 76, 88 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
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in the Interest of B. N. M., a Child (2022)
See In re A.L.H., 468 S.W.3d 738, 744 (Tex. App.—Houston [14th Dist.] 2015, no pet.) (citing In re D.T., 34 S.W.3d 625, 633 (Tex. App.—Fort Worth 2000, pet. denied); In re A.S., 261 S.W.3d 76, 90 (Tex. App.—Houston [14th Dist.] 2008, pet. denied)). 3 C.M. does not challenge that the Department made reasonable efforts to return the child or that he has not regularly visited or maintained significant contact with B.N.M.
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in the Interest of Z.Q.N., a Child (2019)
See A.S., 261 S.W.3d at 86 (“While unquestionably, an exercise of poor judgment, Veronica’s use of marijuana on a single occasion, standing alone, does not rise to the level of a conscious course of conduct.”).
“While unquestionably, an exercise of poor judgment, Veronica’s use of marijuana on a single occasion, standing alone, does not rise to the level of a conscious course of conduct.”
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in the Interest of M.A.S.L. and K.J.L., Children (2018)
See A.S., 261 S.W.3d at 89 (“[I]ncarcerated parent[s] can provide [a] safe environment . . . through identification of [a] friend, relative, or spouse as [a] care provider”) (citing In re D.S.A., 113 S.W.3d 567, 573 (Tex. App.—Amarillo 2003, no pet.)).
“[I]ncarcerated parent[s] can provide [a] safe environment . . . through identification of [a] friend, relative, or spouse as [a] care provider”
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in the Interest of B.F., P.M.F. AKA P.F., Children (2017)
See A.S., 261 S.W.3d at 86 (“While unquestionably, an exercise of poor judgment, Veronica’s use of marijuana on a single occasion, standing alone, 12 does not rise to the level of a conscious course of conduct.”); see also In re H.L.F., No. 12-11-00243-CV, 2012 WL 5993726 , at *5 (Tex. App.—Tyler Nov. 30, 2012, pet. denied) (mem. op.) (cited by Mother for proposition that mere fact of drug use during pregnancy does not mean termination is automatic).
“While unquestionably, an exercise of poor judgment, Veronica’s use of marijuana on a single occasion, standing alone, 12 does not rise to the level of a conscious course of conduct.”
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in the Interest of A.K.L. and S.A.A.P. , Children (2016)
See id. (“Generally, implementation of a family service plan by [DFPS] is considered a reasonable effort to return a child to the parent.”); In re K.G., 350 S.W.3d 338, 354 (Tex. App.—Fort Worth 2011, pet. denied) (holding that evidence was legally and factually sufficient to establish that DFPS made reasonable effort to return child when caseworker testified that she had tried to facilitate reunification by providing services to mother, encouraging mother to seek help for h…
“Generally, implementation of a family service plan by [DFPS] is considered a reasonable effort to return a child to the parent.”
A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied) (internal citation omitted).
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In the Interest of P.M.B., J.Q.B., M.B. AKA Baby Girl B., K.L.B. AKA K.L.B., Children v. Department of Family… (2026)
Once we overrule a parents challenge to an order terminating her parental rights, the trial court’s appointment of DFPS as sole managing conservator is a “consequence of the termination.” In re J.D.G., 570 S.W.3d at 856 ; In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
Although both subsections (D) and (E) both focus on endangerment, “they differ with regard to the source and proof of endangerment.” In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied) (citing In re S.M.L., 171 S.W.3d 472, 477 (Tex. App.—Houston [14th Dist.] 2005, no pet.), overruled on other grounds by In re L.C.L., 599 S.W.3d 79 (Tex. App.—Houston [14th Dist.] 2020, pet. denied) (en banc)).
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In the Interest of J.C.D.Y. A/K/A J.Y., J.E.D.Y. AKA J.Y., M.M.D.Y. AKA M.Y., J.T.D.Y., AKA J.Y. Children v. … (2026)
Once we overrule a parent’s challenge to an order terminating her parental rights, the trial court’s appointment of the Department or another person as the child’s sole managing conservator may be considered a 60 “consequence of the termination.” In re A.S., 261 S.W.3d 76, 92 (Tex. App.— Houston [14th Dist.] 2008, pet. denied); see also In re J.D.G., 570 S.W.3d at 856 . 8 Because we have overruled Mother’s challenge to the portion of the trial court’s decree terminating her …
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In the Interest of J.C.D.Y. A/K/A J.Y., J.E.D.Y. AKA J.Y., M.M.D.Y. AKA M.Y., J.T.D.Y., AKA J.Y. Children v. … (2026)
Once we overrule a parent’s challenge to an order terminating her parental rights, the trial court’s appointment of the Department or another person as the child’s sole managing conservator may be considered a 60 “consequence of the termination.” In re A.S., 261 S.W.3d 76, 92 (Tex. App.— Houston [14th Dist.] 2008, pet. denied); see also In re J.D.G., 570 S.W.3d at 856 .8 Because we have overruled Mother’s challenge to the portion of the trial court’s decree terminating her p…
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In the Interest of M.M.H.H. AKA M.H., a Child v. Department of Family and Protective Services (2025)
Once we overrule a parents challenge to an order terminating her parental rights, the trial court’s appointment of DFPS as sole managing conservator is a “consequence of the termination.” In re J.D.G., 570 S.W.3d at 856; In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
Once we overrule a parent’s challenge to an order terminating his parental rights, the trial court’s appointment of DFPS as sole managing conservator may be considered a “consequence of the termination.” In re J.D.G., 570 S.W.3d at 856 ; In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied) (citation omitted). 25 Because we have overruled Father’s challenges to the portion of the trial court’s decree terminating his parental rights, the order dives…
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In the Interest of Z. J. G., J. R. G. and N. L. G. v. Department of Family and Protective Services (2025)
Once we overrule a parent’s challenge to an order terminating her parental rights, the trial court’s appointment of the Department as sole managing conservator may be considered a “consequence of the termination.” In re J.D.G., 570 S.W.3d at 856 ; In re A.S., 261 S.W.3d 76, 92 (Tex. App.— Houston [14th Dist.] 2008, pet. denied).
Cf., In re A.S., 261 S.W.3d 76, 86 (Tex. App.—Houston [14th Dist.] 2008, pet. denied) (evidence insufficient to support endangerment finding where it was uncontroverted that children did not witness two occasions of domestic violence).
Once we overrule a parent’s challenge to an order terminating his parental rights, the trial court’s appointment of DFPS as sole managing conservator may be considered a “consequence of the termination.” In re J.D.G., 570 S.W.3d at 856 ; In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied) (citation omitted). 28 Because we have overruled Father’s challenges to the portion of the trial court’s order terminating his parental rights, the order divest…
Though Mother did suggest her brother as a proposed placement, the Department’s caseworker, Ochoa, testified that he was determined to not be suitable because “he was incarcerated for drugs.” Cf. In re A.S., 261 S.W.3d 76, 90 (Tex. App.—Houston [14th Dist.] 2008, pet. denied) (finding Department failed to meet its burden to show appellant demonstrated inability to provide child with safe environment when no evidence established whether or why Department rejected appellant’s …
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In the Interest of E. A. R. AKA A. E. R. v. Department of Family and Protective Services (2024)
In re A.S., 261 S.W.3d 76, 83 (Tex. App.— Houston [14th Dist.] 2008, pet. denied).
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In the Interest of R.R and RR a Minor Child v. the Department of Family and Protective Services; Marcus Omar … (2024)
In re J.I.G., No. 01-18-00023- CV, 2018 WL 3233874 , at *8 (Tex. App.—Houston [1st Dist.] July 3, 2018, no pet.) (mem. op.) (citing In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied)).
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In the Interest of E.G.A. and G.S.A., Children v. the Department of Family and Protective Services (2024)
In re J.I.G., No. 01-18-00023-CV, 2018 WL 3233874 , at *8 (Tex. App.—Houston [1st Dist.] July 3, 2018, no pet.) (mem. op.) (citing In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied)).
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In the Interest of A.M.A., N.X.A., N.A.A., and A.J.A., Children v. the Department of Family and Protective Se… (2024)
In re J.I.G., No. 01-18-00023-CV, 2018 WL 3233874 , at *8 (Tex. App.—Houston [1st Dist.] July 3, 2018, no pet.) (mem. op.) (citing In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied)).
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In the Interest of E.A.O.E. AKA E.O.E., G.E.O.E. AKA G.O.E., Children v. the State of Texas (2024)
In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
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In the Interest of C.C. AKA C.C., Child v. Department of Family and Protective Services (2024)
In re A.S., 261 S.W.3d 76, 83 (Tex. App.— Houston [14th Dist.] 2008, pet. denied).
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In the Interest of L. R. D. and K. A. M. v. Department of Family and Protective Services (2024)
In re J.I.G., No. 01-18-00023- CV, 2018 WL 3233874 , at *8 (Tex. App.—Houston [1st Dist.] July 3, 2018, no pet.) (mem. op.) (citing In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied)).
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J.M. v. Department of Family and Protective Services (2023)
The trial court’s appointment of the Department as sole managing conservator may be considered a “consequence of the termination pursuant to Family Code section 161.207.” In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
“A ‘parent’s use of narcotics and its effect on his or her ability to parent may qualify as an endangering course of conduct.’” S.W. v. Texas Dep’t of Fam. & Protective Servs., No. 03-22-00239-CV, 2022 WL 5125206 , at *14 (Tex. App.—Austin Oct. 5, 2022, no pet.) (mem. op.) (quoting In re J.O.A., 283 S.W.3d at 345 ). 18 Father downplays this evidence by citing examples of courts rejecting endangerment findings based on a couple documented incidents of drug use, see, e,g., In …
CODE ANN. § 161.207; Wiley v. Spratlan, 543 S.W.2d at 350 ; In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied) (citing In re D.N.C., 252 S.W.3d at 318 ).
In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
See In re J.A.J., 243 S.W.3d at 616-17 ; In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
Once we overrule a parent’s challenge to an order terminating her parental rights, the trial court’s appointment of the Department as sole managing conservator may be considered a “consequence of the termination.” In re J.D.G., 570 S.W.3d at 856 ; In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
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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… (2023)
In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
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in the Interest of E. S. T. AKA E.T. a Child v. Department of Family and Protective Services (2022)
Once we overrule a parent’s challenge to an order terminating her parental rights, the trial court’s appointment of the Department or another person as the child’s sole managing conservator may be considered a “consequence of the termination.” In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied); see also In re J.D.G., 570 S.W.3d at 856.
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in the Interest of E.A.D., a Child (2022)
In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
In re A.S., 261 S.W.3d 76, 83 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
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R.G. v. Department of Family and Protective Services (2022)
The trial court’s appointment of the Department as sole managing conservator may be considered a “consequence of the termination pursuant to Family Code section 161.207.” In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
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in the Interest of A. J. A. A/K/A Unknown Female A/K/A A. A., a Child v. Department of Family and Protective … (2021)
Once we overrule a parent’s challenge to an order terminating his parental rights, the trial court’s appointment of the Department as sole managing conservator may be considered a “consequence of the termination.” In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied); see also In re J.D.G., 570 S.W.3d at 856 . 34 Because we have overruled Father’s challenges to the portion of the trial court’s order terminating his parental rights, the order divest…
See, e.g., id. at 752 (“While unquestionably an exercise of poor judgment, Father’s use of methamphetamines on two occasions, standing alone, does not rise to the level of a conscious course of conduct.”); In re A.S., 261 S.W.3d 76, 86 (Tex. App.—Houston [14th Dist.] 2008, pet. denied) (concluding that “a single use of marijuana does not constitute a ‘voluntary, deliberate, and conscious course of conduct’ sufficient to support a termination finding under subsection (E)”); R…
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in the Interest of T. L. B., A. J. and L. J. v. Department of Family and Protective Services (2021)
Once we overrule a parent’s challenge to an order terminating her parental rights, the trial court’s appointment of the Department as sole managing conservator may be considered a “consequence of the termination.” In re D.K.W., Jr., 2017 WL 6520439 , at *5 (quoting In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied)).
See In re A.L.H., 468 S.W.3d 738, 744 (Tex. App.—Houston [14th Dist.] 2015, no pet.) (citing In re D.T., 34 S.W.3d at 633 ; In re A.S., 261 S.W.3d 76, 90 (Tex. App.—Houston [14th Dist.] 2008, pet. denied)).
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in the Interest of A.C., K. L.C. III and L. C. v. Department of Family and Protective Services (2021)
Once we overrule a parent’s challenge to a termination order, the trial court’s appointment of the Department as sole managing conservator may be considered a “consequence of the termination pursuant to Family Code section 161.207.” In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
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in the Interest of Z.A.R. A/K/A Z.R., a Child v. Texas Department of Family and Protective Services (2020)
The trial court’s appointment of the Department as sole managing conservator may be considered a “consequence of the termination pursuant to Family Code section 161.207.” In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
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in the Interest of D.P.G., a Child (2020)
In re A.S., 261 S.W.3d 76, 90 (Tex. App.— Houston [14th Dist.] 2008, pet. denied).
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in the Interest of M.P., a Child (2020)
The trial court’s appointment of the Department as sole managing conservator may be considered a “consequence of the termination pursuant to Family Code section 161.207.” In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).
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in the Interest of J.M. and L.M., Children (2020)
“Once we overrule a parent’s challenge to a termination order, the trial court’s appointment of the Department as sole managing conservator may be considered a ‘consequence of the termination pursuant to Family Code section 161.207.’” In re D.K.W., Jr., No. 01-17-00622-CV, 2017 WL 6520439 , at *5 (Tex. App.—Houston [1st Dist.] Dec. 21, 2017, pet. denied) (mem. op.) (quoting In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied)).
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in the Interest of A.H. (2019)
See In re A.L.H., 468 S.W.3d at 744 (citing In re D.T., 34 S.W.3d 625, 633 (Tex. App.—Fort Worth 2000, pet. denied); In re A.S., 261 S.W.3d 76, 90 (Tex. App.—Houston [14th Dist.] 2008, pet. denied)).
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in the Interest of A.L.J., A.L.J., G.A.G. v. Department of Family and Protective Services (2019)
Once we overrule a parent’s challenge to a termination order, the trial court’s appointment of the Department as sole managing conservator may be considered a “consequence of the termination pursuant to Family Code section 161.207.” In re A.S., 261 S.W.3d 76, 92 (Tex. App.—Houston [14th Dist.] 2008, pet. denied).