C. H. v. Texas Department of Family and Protective Services, 389 S.W.3d 534

C.H. (Mother) appeals a judgment terminating her parental rights to her child C.H., Jr.; the Department sought managing conservatorship.
C.H. was born premature with hydrocephalus and required ongoing medical care and physical therapy.
After birth, C.H. lived with the parents and various relatives; in July 2011 he suffered multiple non-accidental injuries.
The Department investigated; it alleged several grounds for termination, including endangerment under §161.001(1)(D).
The trial court found grounds for termination under §161.001(1)(D) and placed C.H. with his maternal grandmother; the court also ordered termination.
Mother and Father challenged the legal sufficiency of the evidence and the best-interest findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence supports termination under §161.001(1)(D)	Mother argues no clear endangerment proven	Department argues evidence shows endangerment by environment	Yes; evidence legally and factually sufficient to support endangerment
Whether termination was in the child’s best interest	Mother contends best interest not proven	Department argues Holley factors support termination	Yes; best interest supported by Holley factors and evidence

Castaneda v. Texas Department of Protective and Regulatory Services, 148 S.W.3d 509 (Tex.App.—El Paso 2004) (endangerment standard for §161.001(1)(D))
Doyle v. Texas Department of Protective and Regulatory Services, 16 S.W.3d 390 (Tex.App.—El Paso 2000) (endangerment framework for environment in home)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (clear and convincing standards in termination; deference to facts)
In re J.P.B., 180 S.W.3d 570 (Tex. 2005) (legal sufficiency review in termination cases; defer to trial court on credibility)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (standard for legal sufficiency review; robust deference to fact finder)