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Top citers, strongest first. 50 distinct citers.
discussed
Cited as authority (verbatim quote)
S. B., J. B., and C. C. v. Texas Department of Family and Protective Services
(2×)
also: Cited as authority (rule)
eglect can be just as dangerous to the well-being of a child as direct physical abuse.
examined
Cited as authority (verbatim quote)
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, Children v. Texas Department of Family and Protective Services
although there is no evidence that l.c. inflicted direct physical abuse on her children, there is evidence that she neglected their physical needs, and neglect can be just as dangerous to the well-being of a child as direct physical abuse.
discussed
Cited as authority (verbatim quote)
E. E. and C. C. v. Texas Department of Family and Protective Services
(2×)
also: Cited as authority (rule)
neglect can be just as dangerous to the well-being of a child as direct physical abuse.
discussed
Cited as authority (verbatim quote)
in the Interest of I. W., a Child
neglect can be just as dangerous to the well- being of a child as direct physical abuse
discussed
Cited as authority (rule)
Joshua Bridges v. Ashley Mueller and Jeff Mueller
(2×)
also: Cited "see"
For these purposes, “‘[e]ndanger’ means ‘to expose to loss or injury; to jeopardize.’” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam) (quoting Texas Dep’t of Hum.
cited
Cited as authority (rule)
In the Interest of J.N.R., L.A.A.M., K.E.M., and K.J-A.M., Children v. the State of Texas
And “endanger” means “to expose a child to loss or injury, or to jeopardize a child's emotional or mental health.” Id. at *3 (citing In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)).
cited
Cited as authority (rule)
In the Interest of N. N. J., a Child v. the State of Texas
“For both of these provisions, ‘endanger’ means ‘to expose to loss or injury; to jeopardize.’” Id. (quoting In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)).
discussed
Cited as authority (rule)
In the Interest of I.J.A, A.J.A III, A.J.A, X.J.A., & E.J.A., Children v. the State of Texas
Under subsection (E), the trial court must determine “whether there is evidence that a parent’s acts, omissions, or failures to act endangered the child’s physical or emotional well-being.” In re C.J.G., 2019 WL 5580253 , at *2. -3- 04-24-00884-CV Under both subsections (D) and (E), “endanger” means “to expose a child to loss or injury, or to jeopardize a child’s emotional or mental health.” Id. at *3 (citing In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)). “[A] parent need not know for certain that the child is in an endangering environment; awareness of such a potential is s…
cited
Cited as authority (rule)
In the Interest of E.M.-C., a Child v. the State of Texas
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam) (citing Boyd, 727 S.W.2d at 533 ).
cited
Cited as authority (rule)
In the Interest of S.D.T. and S.D.T. v. the State of Texas
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (quoting Boyd, 727 S.W.2d at 533 ).
cited
Cited as authority (rule)
In the Interest of Z. J. G., J. R. G. and N. L. G. v. Department of Family and Protective Services
Id.; In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam).
discussed
Cited as authority (rule)
In the Interest of K.H., a Child v. the State of Texas
(2×)
also: Cited "see"
It is not necessary to have evidence that a parent “inflicted direct physical abuse on [the child],” because “evidence that [the parent] neglected [the child’s] physical needs” shows that “neglect can be just as dangerous to the well-being of a child as direct physical abuse.” In re M.C., 917 S.W.2d 268, 270 (Tex. 1996) (per curiam); see also In re L.L., No. 13-24-00137-CV, 2024 WL 3448029 , at *7 (Tex. App.—Corpus Christi–Edinburg July 18, 2024, no pet.) (mem. op.).
discussed
Cited as authority (rule)
In the Interest of J.T., A.P., L.P., Children v. the State of Texas
“Although ‘endanger’ means more than a threat of metaphysical injury or the possible ill effects of a less-than-ideal family environment, it is not necessary that the conduct be directed at the child or that the child actually suffers injury.” In re G.C.S., 657 S.W.3d 114 , 128 (Tex. App.—El Paso 2022, pet. denied) (quoting In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)); see also Boyd, 727 S.W.2d at 533 .
cited
Cited as authority (rule)
A. L.-E. v. Texas Department of Family and Protective Services
For these purposes, “‘[e]ndanger’ means ‘to expose to loss or injury; to jeopardize.’” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam) (quoting Texas Dep’t of Hum.
discussed
Cited as authority (rule)
In the Interest of H.D.J.A., a Child v. the State of Texas
Under both subsections (D) and (E), “endanger” means “to expose a child to loss or injury, or to jeopardize a child’s emotional or mental health.” Id. at *3 (citing In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)). “[A] parent need not know for certain that the child is in an endangering environment; awareness of such a potential is sufficient.” Id. at *2 (quoting In re R.S.-T., 522 S.W.3d 92, 109 (Tex. App.—San Antonio 2017, no pet.)) (alteration in original).
cited
Cited as authority (rule)
In the Interest of A.J.O., A.J.C., A.L.C., and A.J.C., Children v. the State of Texas
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam); In re J.T.G., 121 S.W.3d at 125 .
cited
Cited as authority (rule)
In the Interest of A.L., a Child v. the State of Texas
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam).
discussed
Cited as authority (rule)
In the Interest of E.A.G.C. v. the State of Texas
Under both subsections (D) and (E), “endanger” means “to expose a child to loss or injury, or to jeopardize a child’s emotional or mental health.” Id. at *3 (citing In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)). “[A] parent need not know for certain that the child is in an endangering environment; awareness of such a potential is sufficient.” Id. at *2 (quoting In re R.S.-T., 522 S.W.3d 92, 109 (Tex. App.—San Antonio 2017, no pet.)) (alteration in original).
cited
Cited as authority (rule)
C. L. and R. H. v. Texas Department of Family and Protective Services
For these purposes, “‘[e]ndanger’ means ‘to expose to loss or injury; to jeopardize.’” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam) (quoting Texas Dep’t of Hum.
discussed
Cited as authority (rule)
L. C. v. Texas Department of Family and Protective Services
Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987)). “‘[E]ndanger’ means more than a threat of metaphysical injury or the possible ill effects of a less-than-ideal family environment, [but] it is not necessary that the conduct be directed at the child or that the child actually suffers injury.” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam) (quoting Boyd, 727 S.W.2d at 533 ); see also A.C. v. Texas Dep’t of Fam. & Protective Servs., 577 S.W.3d 689, 699 (Tex. App.—Austin 2019, pet. denied).
cited
Cited as authority (rule)
In the Interest of K.G., a Child v. the State of Texas
“For both of these provisions, ‘endanger’ means ‘to expose to loss or injury; to jeopardize.’” Id. (quoting In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)).
discussed
Cited as authority (rule)
In the Interest of L.L., L.L., L.L., Children v. the State of Texas
(2×)
also: Cited "see"
There does not need to be evidence that the parent “inflicted direct physical abuse on [the] children,” so long as “there is evidence that [the parent] neglected [the children’s] physical needs, and neglect can be just as dangerous to the well-being of a child as direct physical abuse.” In re M.C., 917 S.W.2d 268, 270 (Tex. 1996) (per curiam); see also In 16 re E.J., No. 14-23-00387-CV, 2023 WL 8043686 , at *9 (Tex. App.—Houston [14th Dist.] Nov. 21, 2023, no pet.) (mem. op.) (“A parent’s failure to properly supervise her young children endangers the children’s physical or em…
discussed
Cited as authority (rule)
In the Interest of C.D.L., a Child v. the State of Texas
Under both subsections (D) and (E), “endanger” means “to expose a child to loss or injury, or to jeopardize a child’s emotional or mental health.” Id. at *3 (citing In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)). “[A] parent need not know for certain that the child is in an endangering environment; awareness of such a potential is sufficient.” Id. at *2 (quoting In re R.S.-T., 522 S.W.3d 92, 109 (Tex. App.—San Antonio 2017, no pet.)) (alteration in original).
discussed
Cited as authority (rule)
M. Y. and D. Y. v. Texas Department of Family and Protective Services
Whether a parent has complied with (or has the ability to comply with) a court-ordered family service plan is not the relevant analysis for 12 subsection (D) or (E); rather, the focus of subsections (D) and (E) is endangerment. 5 When considering whether clear and convincing evidence supports subsection (D) or (E) grounds, our analysis focuses on whether the child’s environment or the parent’s conduct is “endangering,”— that is, exposes the child “to loss or injury; to jeopardize.” In re J.W., 645 S.W.3d at 748 (quoting Texas Dep’t of Human Servs. v. Boyd, 727 S.W.2d 531, 533 (…
discussed
Cited as authority (rule)
In the Interest of A.K.B., C.J.B., and M.L.A.B. v. the State of Texas
“Endanger” means “to expose [the children] to loss or injury or to jeopardize [their] emotional or mental health.” In re C.J.G., No. 04-19-00237-CV, 2019 WL 5580253 , at *3 (Tex. App.—San Antonio Oct. 30, 2019, no pet.) (citing In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)).
cited
Cited as authority (rule)
A. S. v. Texas Department of Family and Protective Services
For these purposes, “‘[e]ndanger’ means ‘to expose to loss or injury; to jeopardize.’” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam) (quoting Texas Dep’t of Hum.
cited
Cited as authority (rule)
In the Interest of I. C., a Child v. the State of Texas
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam); In re J.T.G., 121 S.W.3d 117, 125 (Tex. App.—Fort Worth 2003, no pet.).
discussed
Cited as authority (rule)
In the Interest of H.R.S. v. the State of Texas
Yet the most current document that Mother’s attorney presented in the trial to establish that 40In re M.C., 917 S.W.2d 268, 269 (Tex. 1996). 41See J.O.A., 283 S.W.3d at 345 ; In the Int. of B.P., No. 09-22-00031- CV, 2022 Tex. App. LEXIS 4277 , at *25 (Tex. App.—Beaumont June 23, 2022, no pet.). 42J.O.A., 283 S.W.3d at 345 ; In re D.P., 2022 Tex. App. LEXIS 5279 , at *25. 27 Mother was still pursing treatment was a document dated April 20, 2023.
discussed
Cited as authority (rule)
In the Interest of J.A.B., J.LB., and J.B., Children v. the State of Texas
Under both subsections, “endanger” means “to expose a child to loss or injury, or to jeopardize a child’s emotional or mental health.” Id. at *3 (citing In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)). “[A] parent need not know for certain that the child is in an endangering environment, awareness of such a potential is sufficient.” Id. at *2 (quoting In re R.S.-T., 522 S.W.3d 92, 109 (Tex. App.—San Antonio 2017, no pet.)).
cited
Cited as authority (rule)
In the Interest of A.V.G.-P. and A.O.G.-P., Children v. the State of Texas
"Endanger" means "to expose a child to loss or injury, or to jeopardize a child's emotional or mental health." In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam).
cited
Cited as authority (rule)
In the Interest of Z.K.R., a Child v. the State of Texas
“For both of these provisions, ‘endanger’ means ‘to expose to loss or injury; to 15 jeopardize.’” Id. (quoting In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)).
discussed
Cited as authority (rule)
In the Interest of A.C.T.M., a Child v. the State of Texas
Endanger “means to expose to loss or injury, to jeopardize.” In re N.J.H., 575 S.W.3d 822, 831 (Tex. App.—Houston [1st Dist.] 2018, pet. denied) (citing In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam)).
discussed
Cited as authority (rule)
M. R., C. B. and J. R. v. Texas Department of Family and Protective Services
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam) (citing Texas Dep’t of Human Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987)). “‘Endangerment does not have to be established as an independent proposition, but can be inferred from parental misconduct alone,’ and courts may look to conduct ‘before the child’s birth and both before and after the child has been removed by the Department.’” S.B. v. Texas Dep’t of Fam. & Protective Servs., 654 S.W.3d 246 , 253 (Tex. App.—Austin 2022, pet. denied) (quoting Pruitt v. Texas Dep’t of Fam. & Protective Servs., No. 03-10-000…
discussed
Cited as authority (rule)
In the Interest of L. R. D. and K. A. M. v. Department of Family and Protective Services
Tex. Dep’t of Human Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987); In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam) (holding that “endanger” means to expose child to loss or injury or to jeopardize child’s emotional or physical health); In re S.R., 452 S.W.3d 351, 360 (Tex. App.—Houston [14th Dist.] 2014, pet. denied).
cited
Cited as authority (rule)
In the Interest of A.R., and N.R., Children v. the State of Texas
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam).
cited
Cited as authority (rule)
In the Interest of A.C., and S.M., Children v. the State of Texas
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam).
discussed
Cited as authority (rule)
In the Interest of D.W., A.W., I.W., I.W., Children v. the State of Texas
In re D.L.W.W., 617 S.W.3d 64 , 78 (Tex. App.—Houston [1st Dist.] 2020, no pet.) (quoting In re J.T.G., 121 S.W.3d 117 , 125 (Tex. App.—Fort Worth 2003, no pet.)). 12 “For both of these provisions, ‘endanger’ means ‘to expose to loss or injury; to jeopardize.’” Id. (quoting In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam)).
discussed
Cited as authority (rule)
T. D. v. Texas Department of Family and Protective Services
(2×)
also: Cited "see"
For these purposes, “‘[e]ndanger’ means ‘to expose to loss or injury; to jeopardize.’” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam) (quoting Texas Dep’t of Hum.
cited
Cited as authority (rule)
In the Interest of C.K.C., a Child v. the State of Texas
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam).
discussed
Cited as authority (rule)
In the Interest of D. J. R., D.J.O. and I.L.A., Children v. the State of Texas
“Endanger” means “to expose a child to loss or injury, or to jeopardize a child’s emotional or mental health.” Id. at *3 (citing In re M.C., 917 S.W.2d 268, 269 (Tex. 1996)). “[A] parent need not know for certain that the child is in an endangering environment, awareness of such a potential is sufficient.” Id. at *2 (quoting In re R.S.-T., 522 S.W.3d 92, 109 (Tex. App.—San Antonio 2017, no pet.)). “‘[I]n evaluating endangerment under subsection D, we consider the child’s environment before the Department obtained custody of the child.’” Id. (quoting In re S.R., 452 S.…
discussed
Cited as authority (rule)
In the Interest of S.L.G and A.J.G, Children v. the State of Texas
In re M.C., 917 S.W.2d 268, 270 (Tex. 1996) (a parent 8 endangered the children by allowing them to live in extraordinarily unsanitary conditions, which included the presence of garbage, animal feces, and roach infestation); In re K.S.O.B., No. 01-18-00860-CV, 2019 WL 1246348 , at *13 (Tex. App.—Houston [1st Dist.] Mar. 19, 2019, no pet.) (mem. op.) (the children were living in deplorable conditions and the home was unsanitary and had rancid odors); In re C.L.C., 119 S.W.3d 382, 392 (Tex. App.—Tyler 2003, no pet.); In re P.E.W., 105 S.W.3d 771, 777 (Tex. App.—Amarillo 2003, no pet.) (the…
discussed
Cited as authority (rule)
M. E. and D. R. v. Texas Department of Family and Protective Services
Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987)). “‘[E]ndanger’ means more than a threat of metaphysical injury or the possible ill effects of a less-than-ideal family environment, [but] it is not necessary that the conduct be directed at the child or that the child actually suffers injury.” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (quoting Boyd, 727 S.W.2d at 533 ); see also A.C., 577 S.W.3d at 699.
cited
Cited as authority (rule)
In the Interest of N.W., a Child v. the State of Texas
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam).
discussed
Cited as authority (rule)
A. R. v. Texas Department of Family and Protective Services
Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987)). “‘[E]ndanger’ means more than a threat of metaphysical injury or the possible ill effects of a less-than-ideal family environment, [but] it is not necessary that the conduct be directed at the child or that the child actually suffers injury.” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (quoting Boyd, 727 S.W.2d at 533 ); see also A.C. v. Texas Dep’t of Fam. & Protective Servs., 577 S.W.3d 689, 699 (Tex. App.—Austin 2019, pet. denied).
discussed
Cited as authority (rule)
E. J. v. Texas Department of Family and Protective Services
Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987)). “‘[E]ndanger’ means more than a threat of metaphysical injury or the possible ill effects of a less-than-ideal family environment, [but] it is not necessary that the conduct be directed at the child or that the child actually suffers injury.” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (quoting Boyd, 727 S.W.2d at 533 ); see also A.C. v. Texas Dep’t of Fam. & Protective Servs., 577 S.W.3d 689, 699 (Tex. App.—Austin 2019, pet. denied).
discussed
Cited as authority (rule)
In the Interest of L.N., a Child v. the State of Texas
(2×)
also: Cited "see"
"Endanger" means "to expose a child to loss or injury, or to jeopardize a child's emotional or mental health." In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam).
cited
Cited as authority (rule)
In the Interest of M.I.J., a Child v. the State of Texas
Endanger means “‘to expose to loss or injury; to jeopardize.’” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996).
cited
Cited as authority (rule)
In the Interest of R.J.N., a Child v. the State of Texas
In this context, "endanger" means "to expose to loss or injury; to jeopardize." In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam).
cited
Cited as authority (rule)
In the Interest of Z.E., Child(ren) v. the State of Texas
In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (per curiam); In re J.D.B., 435 S.W.3d 452, 463 (Tex. App.—Dallas 2014, no pet.).
discussed
Cited as authority (rule)
A. B. v. Texas Department of Family and Protective Services
Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987)). “‘[E]ndanger’ means more than a threat of metaphysical injury or the possible ill effects of a less-than-ideal family environment, [but] it is not necessary that the conduct be directed at the child or that the child actually suffers injury.” In re M.C., 917 S.W.2d 268, 269 (Tex. 1996) (quoting Boyd, 727 S.W.2d at 533 ); see also A.C. v. Texas Dep’t of Fam. & Protective Servs., 577 S.W.3d 689, 699 (Tex. App.—Austin 2019, pet. denied).
In re M.C., D.C., and C.W., Children, Petitioners.
95-0871.
Texas Supreme Court.
Mar 7, 1996.
Per Curiam.
Published
Citer courts: Court of Appeals of Texas (6) · Court of Criminal Appeals of T… (1)
[*269] Craig Carter, Austin, for Petitioners.
Isaac M. Castro and Jeffrey S. Davis, Hamlin, for Respondent.
PER CURIAM.
Following a jury trial, the trial court rendered judgment in this case terminating L.C.'s parental rights to her three children, M.C., D.C., and C.W. The court of appeals held that the evidence was "not sufficient" to support the judgment because "[t]here was no evidence that L.C. `endangered' her children." ___ S.W.2d ___, ___[, 1996 WL 102361]. Finding that the Texas Department of Protective and Regulatory Services (TDPRS) presented legally sufficient evidence to support the trial court's judgment, we reverse the judgment of the court of appeals and remand this case to that court so that it may address L.C.'s remaining points of error. See Havner v. E-Z Mart Stores, Inc., 825 S.W.2d 456, 462 (Tex.1992).
The Legislature has authorized the termination of parental rights if the parent has:
(D) knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endanger the physical or emotional well-being of the child; or
(E) engaged in conduct or knowingly placed the child with persons who engaged in conduct which endangers the physical or emotional well-being of the child.
TEX.FAM.CODE § 15.02(1)(D) & (E) (current version at TEX.FAM.CODE § 161.001). "Endanger" means "to expose to loss or injury; to jeopardize." Texas Dep't of Human Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987). Although "`endanger' means more than a threat of metaphysical injury or the possible ill effects of a less-than-ideal family environment, it is not necessary that the conduct be directed at the child or that the child actually suffers injury." Id.
On at least two occasions, L.C. left the children alone in potentially dangerous[*270] situations. In June 1991, a police officer found the two older children, ages two and four, wandering on a highway at night. When he brought the children home, he found C.W., an infant, alone. L.C. arrived five or ten minutes later and, according to the officer, she appeared unconcerned that the children had been alone. Another witness testified that one day while she was visiting her mother, L.C. left her children alone in a car while it was running and the children drove the car into a neighbor's house.
There was also evidence that L.C. jeopardized her children's health by allowing them to live in extraordinarily unsanitary conditions. Caseworkers and counselors who visited L.C.'s home testified that it was infested with roaches, that the children ate food off the floor and out of the garbage, and that the floor and furniture were littered with food, dirty clothes, garbage, and feces. The children often wore soiled diapers and clothes, and sometimes had dried food, feces, and mucus on their skin and clothes. Francis Hardy, a foster parent for the children, testified that when the children arrived at her house, they were unclean and had a bad odor. D.C. had dead cockroaches matted in her hair. When Mrs. Hardy cleaned C.W.'s bottles, she found dead roaches inside.
Cynthia Asbury, a Child Protective Services Specialist, testified that L.C. was not only indifferent to the unsanitary conditions of her house and her children, but also unresponsive to the children's health problems. During one summer, L.C. moved her family from her mother's home to a rented house, apparently before utility services were connected. Ms. Asbury found the children suffering from severe diarrhea and vomiting, without plumbing or drinking water. Ms. Asbury also testified that the children were often sick with diarrhea and vomiting, but that L.C. rarely took them to the doctor. Ms. Asbury sometimes arranged medical appointments for the children when they were ill, but, usually, L.C. did not bring them to their appointments.
Based on the evidence in the record, we conclude that the Texas Department of Protective and Regulatory Services presented more than a scintilla of evidence that L.C. endangered her children's physical well-being. Although there is no evidence that L.C. inflicted direct physical abuse on her children, there is evidence that she neglected their physical needs, and neglect can be just as dangerous to the well-being of a child as direct physical abuse.[1]
Accordingly, we grant the Department's application for writ of error and, without hearing oral argument, reverse the judgment of the court of appeals and remand this case to that court so that it may address L.C.'s remaining points of error. See TEX.R.APP.P. 170.
1 In its brief, TDPRS notes that in Fiscal Year 1994, 102 children died in Texas from either abuse or neglect. Fifty-five of these deaths were the result of neglect.