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18 Texas opinions name it 2 courts 2014–2026 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.
| Case | Followed | Cited |
|---|---|---|
In Re RFgreen2 sentences2023See In re R.F., 115 S.W.3d 804, 811 (Tex. App.—Dallas 2003, no pet.) (providing that as part of the endangering-conduct analysis, a court may consider a parent’s failure to complete a service plan). 2023See In re R.F., 115 S.W.3d 804, 811 (Tex. App.—Dallas 2003, no pet.) (considering, as part of the endangering-conduct analysis, a parent’s failure to complete a service plan). | 13 | 13 |
In Re J.O.A.green2 sentences2026We identify some of the pertinent parental conduct that we can consider in an endangering-conduct analysis: • “Domestic violence, want of self[-]control, and propensity for violence,” In re A.L.W., No. 04-24-00874-CV, 2025 WL 2158523 , at *4 (Tex. App.—San Antonio July 30, 2025, pet. denied) (mem. op.) (quoting In re J.I.T.P., 99 S.W.3d 841, 845 (Tex. App.—Houston [14th Dist.] 2003, no pet.)); see also J.O.A., 283 S.W.3d at 346 ; • Conduct toward another child or a domestic partner, In re L.A., No. 02-25-00368-CV, 2025 WL 3683989 , at *4 (Tex. App.—Fort Worth Dec. 18, 2025, no pet. h.) (mem. o 2026We identify some of the pertinent parental conduct that we can consider in an endangering-conduct analysis: • “Domestic violence, want of self[-]control, and propensity for violence,” In re A.L.W., No. 04-24-00874-CV, 2025 WL 2158523 , at *4 (Tex. App.—San Antonio July 30, 2025, pet. denied) (mem. op.) (quoting In re J.I.T.P., 99 S.W.3d 841, 845 (Tex. App.—Houston [14th Dist.] 2003, no pet.)); see also J.O.A., 283 S.W.3d at 346 ; • Conduct toward another child or a domestic partner, In re L.A., No. 02-25-00368-CV, 2025 WL 3683989 , at *4 (Tex. App.—Fort Worth Dec. 18, 2025, no pet. h.) (mem. o | 2 | 2 |
Robinson v. Texas Department of Protective & Regulatory Servicesgreen2 sentences2020In re X.S., No. 07-17-00422-CV, 2018 Tex. App. LEXIS, at *9-10 (Tex. App.—Amarillo April 18, 2018, no pet.) (mem. op.); Robinson v. Tex. Dep’t of 7 Protective & Regulatory Servs., 89 S.W.3d 679, 686-87 (Tex. App.—Houston [1st Dist.] 2002, no pet.). 2020In re X.S., No. 07-17-00422-CV, 2018 Tex. App. LEXIS 2735 , at *9-10 (Tex. App.—Amarillo April 18, 2018, no pet.) (mem. op.); Robinson v. Tex. Dep’t of Protective & Regulatory Servs., 89 S.W.3d 679, 686-87 (Tex. App.—Houston [1st Dist.] 2002, no pet.). | 2 | 2 |
In Re JITPgreen1 sentence2026We identify some of the pertinent parental conduct that we can consider in an endangering-conduct analysis: • “Domestic violence, want of self[-]control, and propensity for violence,” In re A.L.W., No. 04-24-00874-CV, 2025 WL 2158523 , at *4 (Tex. App.—San Antonio July 30, 2025, pet. denied) (mem. op.) (quoting In re J.I.T.P., 99 S.W.3d 841, 845 (Tex. App.—Houston [14th Dist.] 2003, no pet.)); see also J.O.A., 283 S.W.3d at 346 ; • Conduct toward another child or a domestic partner, In re L.A., No. 02-25-00368-CV, 2025 WL 3683989 , at *4 (Tex. App.—Fort Worth Dec. 18, 2025, no pet. h.) (mem. o | 1 | 1 |
Jordan v. Dosseygreen1 sentence2026We identify some of the pertinent parental conduct that we can consider in an endangering-conduct analysis: • “Domestic violence, want of self[-]control, and propensity for violence,” In re A.L.W., No. 04-24-00874-CV, 2025 WL 2158523 , at *4 (Tex. App.—San Antonio July 30, 2025, pet. denied) (mem. op.) (quoting In re J.I.T.P., 99 S.W.3d 841, 845 (Tex. App.—Houston [14th Dist.] 2003, no pet.)); see also J.O.A., 283 S.W.3d at 346 ; • Conduct toward another child or a domestic partner, In re L.A., No. 02-25-00368-CV, 2025 WL 3683989 , at *4 (Tex. App.—Fort Worth Dec. 18, 2025, no pet. h.) (mem. o | 1 | 1 |
In re R.A.G.green1 sentence2025And Father’s visiting the children only twice while the case was pending is another example. “[A] trial court may consider in its analysis a parent’s failure to visit, which can endanger the child’s emotional well-being.” In re J.G., No. 02-21-00257-CV, 2022 WL 187983 , at *9 (Tex. App.—Fort Worth Jan. 20, 2022, no pet.) (mem. op.) (citing M.K., 2020 WL 1949629 , at *6); In re R.A.G., 545 S.W.3d 645, 652 (Tex. App.—El Paso 2017, no pet.) (“[A] fact finder may infer that a parent’s lack of contact with the child and absence from the child’s life endangered the child’s emotional well-being.”). | 1 | 1 |
In Re MLBgreen2 sentences2024In re M.L.B., 269 S.W.3d 757, 760 (Tex. App.—Beaumont 2008, no pet.). • Also as part of the endangering-conduct analysis, a court may consider a parent’s failure to complete a service plan. 2024In re M.L.B., 269 S.W.3d 757, 760 (Tex. App.—Beaumont 2008, no pet.). • Also as part of the endangering-conduct analysis, a court may consider a parent’s failure to complete a service plan. | 1 | 1 |
In Re DMgreen1 sentence2023“The [Department] need not show incarceration was a result of a course of conduct endangering the child; it need only show incarceration was part of a course of conduct endangering the child.” In re D.M., 58 S.W.3d 801, 812 (Tex. App.—Fort Worth 2001, no pet.) (emphasis added). • Additionally, “[a] parent’s mental health is frequently considered in reviewing the sufficiency of the evidence under endangerment grounds.” In re J.P.-L., 592 S.W.3d 559 , 583 n.26 (Tex. App.—Fort Worth 2019, pet. denied). • Also as part of the endangering-conduct analysis, a court may consider a parent’s failure to | 1 | 1 |
In Re HRMgreen1 sentence2023In re H.R.M., 209 S.W.3d 105, 108 (Tex. 2006). | 1 | 1 |
In the Interest of E.N.C., J.A.C., S.A.L., N.A.G. and C.G.L.green1 sentence2014See E.N.C., 384 S.W.3d at 805 ; Boyd, 727 S.W.2d at 533–34; K.C.F., 2014 WL 2538624 , at *12; R.F., 115 S.W.3d at 811 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
H. W. J. v. State Department of Public Welfare
green
1 sentence2014H.W.J., like Boyd, looked at terminating a parent’s parental rights when the parent’s persistent criminality, which did not directly endanger the child, led to protracted incarceration. 543 S.W.2d at 10–11. gone to jail twice in the two months preceding the children’s removal, and that he had warrants for his arrest at the time the children were removed; and that he had failed to complete his services—all of which can be considered in an endangering-environment analysis and an endangering-conduct analysis under subsections (D) and (E). | 1 | 2014–2014 |
Texas Department of Human Services v. Boyd
green
1 sentence2014See E.N.C., 384 S.W.3d at 805 ; Boyd, 727 S.W.2d at 533–34; K.C.F., 2014 WL 2538624 , at *12; R.F., 115 S.W.3d at 811 . | 1 | 2014–2014 |
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.