clear and convincing evidentiary standard (Texas) · Go Syfert
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clear and convincing evidentiary standard in Texas

29 Texas opinions name it 2 courts 1998–2024 10 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
In Re J.O.A.green
tex · 2009 · cited in 12 Texas opinions naming this issue, 2010–2024
2 sentences

2020Reviewing Mother’s legal sufficiency challenge under the clear and convincing evidentiary standard, we “should look at all the evidence in the light most favorable to the finding to determine whether a reasonable trier of fact could have formed a firm belief or conviction that its finding was true.” In re J.O.A., 283 S.W.3d 336, 344 (Tex. 2009).

2019Reviewing Father’s legal sufficiency challenge under the clear-and- convincing evidentiary standard, we “should look at all the evidence in the light most favorable to the finding to determine whether a reasonable trier of fact could have formed a firm belief or conviction that its finding was true.” In re J.O.A., 283 S.W.3d 336, 344 (Tex. 2009).

1212
In the Interest of E.N.C., J.A.C., S.A.L., N.A.G. and C.G.L.green
tex · 2012 · cited in 4 Texas opinions naming this issue, 2013–2023
2 sentences

2023See In re E.N.C., 384 S.W.3d 796 , 809–10 (Tex. 2012) (“Due process commands that courts apply the clear and convincing evidentiary standard in parental rights termination cases.”); In re T.S., No. 01-22-00054-CV, 2022 WL 4474277 , at *28 (Tex. App.— Houston [1st Dist.] Sept. 27, 2022, no pet.) (mem. op.).

2015In re E.N.C., 384 S.W.3d at 809 (“due process command that courts apply the clear and convincing evidentiary standard in parental rights termination cases.”) PRAYER Appellant, A.L.T., prays that the Court reverse the judgment terminating her parental rights to A.L.W. and A.N.W.

44
Santosky v. Kramergreen
scotus · 1982 · cited in 3 Texas opinions naming this issue, 2013–2023
2 sentences

2023See In 34 re E.N.C., 384 S.W.3d at 802 ; see also Santosky v. Kramer, 455 U.S. 745 , 753–54 (1982).

2013A. Standard of Review “Due process commands that courts apply the clear and convincing evidentiary standard in parental rights termination cases.” In re E.N.C., 384 S.W.3d 796, 809 (Tex. 2012) (citing Santosky v. Kramer, 455 U.S. 745, 769 (1982)); see In re B.G., 317 S.W.3d 250, 257 (Tex. 2010) (observing that a parental rights termination case implicates “fundamental liberties” and “a parent’s interest in maintaining custody of and raising his or her child is paramount” (quoting In re M.S., 115 S.W.3d 534, 547 (Tex. 2003))).

33
In Re BGgreen
tex · 2010 · cited in 2 Texas opinions naming this issue, 2013–2019
2 sentences

2019See Santosky v. Kramer, 455 U.S. 745, 769 , 102 S. Ct. 1388, 1403 , 71 L.Ed.2d 599 (1982); J.F.C., 96 S.W.3d at 263 ; see also In re B.G., 317 S.W.3d 250, 257 (Tex. 2010) (observing that a parental rights termination case implicates “fundamental liberties” and “a parent’s interest in maintaining custody of and raising his or her child is paramount” (quoting In re M.S., 115 S.W.3d 534, 547 (Tex. 2003))).

2013A. Standard of Review “Due process commands that courts apply the clear and convincing evidentiary standard in parental rights termination cases.” In re E.N.C., 384 S.W.3d 796, 809 (Tex. 2012) (citing Santosky v. Kramer, 455 U.S. 745, 769 (1982)); see In re B.G., 317 S.W.3d 250, 257 (Tex. 2010) (observing that a parental rights termination case implicates “fundamental liberties” and “a parent’s interest in maintaining custody of and raising his or her child is paramount” (quoting In re M.S., 115 S.W.3d 534, 547 (Tex. 2003))).

22
In Re MSgreen
tex · 2003 · cited in 2 Texas opinions naming this issue, 2013–2019
2 sentences

2019See Santosky v. Kramer, 455 U.S. 745, 769 , 102 S. Ct. 1388, 1403 , 71 L.Ed.2d 599 (1982); J.F.C., 96 S.W.3d at 263 ; see also In re B.G., 317 S.W.3d 250, 257 (Tex. 2010) (observing that a parental rights termination case implicates “fundamental liberties” and “a parent’s interest in maintaining custody of and raising his or her child is paramount” (quoting In re M.S., 115 S.W.3d 534, 547 (Tex. 2003))).

2013A. Standard of Review “Due process commands that courts apply the clear and convincing evidentiary standard in parental rights termination cases.” In re E.N.C., 384 S.W.3d 796, 809 (Tex. 2012) (citing Santosky v. Kramer, 455 U.S. 745, 769 (1982)); see In re B.G., 317 S.W.3d 250, 257 (Tex. 2010) (observing that a parental rights termination case implicates “fundamental liberties” and “a parent’s interest in maintaining custody of and raising his or her child is paramount” (quoting In re M.S., 115 S.W.3d 534, 547 (Tex. 2003))).

22
Stockton Ex Rel. Stockton v. Offenbachgreen
tex · 2011 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024Stockton v. Offenbach, 336 S.W.3d 610, 615 (Tex. 2011). 7 The statute does not impose a clear and convincing evidentiary standard.

11
Phillips Development & Realty, LLC v. LJA Engineering, Inc., F/K/A LJA Engineering & Surveying, Inc.green
texapp · 2016 · cited in 1 Texas opinions naming this issue, 2022–2022
1 sentence

2022See Phillips Dev. & Realty, LLC. v. LJA Eng’g, Inc., 499 S.W.3d 78 , 91 n.8 (Tex. App.—Houston [14th Dist.] 2016, pet. denied). 3 fundamentally fair procedures, including a clear and convincing evidentiary standard, when seeking to terminate parental rights).

11
In Re CHgreen
tex · 2002 · cited in 1 Texas opinions naming this issue, 2020–2020
2 sentences

2020In announcing the clear-and-convincing evidentiary standard, the supreme court stated, “We emphasize that, as appellate courts apply the standard we announce today, they must maintain the respective constitutional roles of juries and appellate courts.” In re C.H., 89 S.W.3d 17, 26 (Tex. 2002).

2020The court further noted, “An appellate court’s review must not be so rigorous that the only factfindings that could withstand review are those established beyond a reasonable doubt.” Id.

11
in the Interest of D.N. and D.N., Childrengreen
texapp · 2013 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015In re E.N.C., 384 S.W.3d at 802 , 809 Subsection (O) includes a specificity requirement and DFPS is required to “support its allegations against [appellant] by clear and convincing evidence; conjecture is not enough.” In re D.N., 405 S.W.3d 863, 878-79 (Tex. App. – Amarillo 2013, no pet.)(citing In re E.N.C., 384 S.W.3d at 810 ) Proof of abuse or neglect is a required element of subsection (O).

11
In Re Heriberto Medranogreen
ca5 · 1992 · cited in 1 Texas opinions naming this issue, 1998–1998
2 sentences

1998See In re Medrano, 956 F.2d 101, 102 (5th Cir.1992).

1998See In re Medrano, 956 F.2d 101, 102 (5th Cir.1992).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Holick v. Smith green
tex · 1985
2 sentences

2015After recognizing these rights, and the fact that a clear and convincing evidentiary standard applies in these cases, the Court explained that this is why "termination proceedings should be strictly scrutinized...." Id.

2015After recognizing these rights, and the fact that a clear and convincing evidentiary standard applies in these cases, the Court explained that this is why "termination proceedings should be strictly scrutinized...." Id.

52002–2015
In Re JFC green
tex · 2002
1 sentence

2019See Santosky v. Kramer, 455 U.S. 745, 769 , 102 S. Ct. 1388, 1403 , 71 L.Ed.2d 599 (1982); J.F.C., 96 S.W.3d at 263 ; see also In re B.G., 317 S.W.3d 250, 257 (Tex. 2010) (observing that a parental rights termination case implicates “fundamental liberties” and “a parent’s interest in maintaining custody of and raising his or her child is paramount” (quoting In re M.S., 115 S.W.3d 534, 547 (Tex. 2003))).

12019–2019
Huckabee v. Time Warner Entertainment Co. green
tex · 2000
1 sentence

2019The supreme court’s decision in Huckabee v. Time Warner Entertainment Co., 19 S.W.3d 413 (2000) is particularly instructive.

12019–2019
In Re JFC green
texapp · 2001
1 sentence

2015In fact, fundamentally enoneous charge on a ‘core issue,’ only attorney did not object to the omission or placement of because the complaint was not preserved in the trial the best interest instruction, he did object to the definition court, does not adhere to Fourteenth Amendment of the clear and convincing evidentiary standard in the procedural due process." Id. (emphasis added). charge.

12015–2015
Stanley v. Illinois green
scotus · 1972
2 sentences

2000I would expressly overrule our precedents of In re B.S.T. and Oadra. .See Stanley v. Illinois, 405 U.S. 645, 651 , 92 S.Ct. 1208 , 1212 31 L.Ed.2d 551 (1972). .

2000I would expressly overrule our precedents of In re B.S.T. and Oadra. .See Stanley v. Illinois, 405 U.S. 645, 651 , 92 S.Ct. 1208 , 1212 31 L.Ed.2d 551 (1972). .

12000–2000

Statutes the citing opinions construe

TX § Tex. Fam. Code § 161.001 (24) TX § Tex. Fam. Code § 101.007 (20) TX § Tex. Fam. Code § 263.307 (16) TX § Tex. Fam. Code § 109.002 (12) TX § Tex. Fam. Code § 107.013 (6) TX § Tex. Fam. Code § 262.201 (6) TX § Tex. Fam. Code § 107.103 (5) TX § Tex. Fam. Code § 262.104 (5) TX § Tex. Fam. Code § 262.105 (5) TX § Tex. Fam. Code § 263.401 (5) TX § Tex. Fam. Code § 263.405 (5) TX § Tex. Fam. Code § 51.11 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 29 (1998–2024) ID 19 (1991–2020) LA 12 (1994–2013) SC 12 (2009–2021) CA 12 (1998–2021) DC 10 (1984–2000) ND 8 (1986–2017) VA 6 (1992–2026) PA 6 (2001–2026) OH 6 (1992–2023) AZ 5 (2000–2025) DE 5 (1982–2014) MD 4 (1988–2006) WA 4 (2009–2019) NY 4 (1997–2026) OR 3 (2001–2003) MI 3 (2015–2026) CO 3 (1998–2025) IA 2 (1994–2013) IL 2 (2012–2019) OK 2 (1982–1982) AL 2 (2008–2008) WY 2 (2011–2011) TN 2 (2018–2018) ME 2 (1986–2000) MO 2 (1995–2019) GA 2 (2013–2013) NC 2 (2006–2024) MN 2 (1999–2007) NV 2 (2009–2009) AK 2 (1995–2017) KY 2 (2011–2019) NH 2 (2011–2012)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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