In Re Jlb, 349 S.W.3d 836

Two children, Samuel (born Jan 2005) and Joshua (born Jan 2007), were removed after CPS found severe neglect and unsafe conditions in the home.
Parents reportedly allowed a man, McCurry, to use the children for panhandling to fund drug use, including crack cocaine.
The initial home showed filthy, cluttered, and hazardous conditions with fire risks, no running water at times, and persistent foul odors.
Children exhibited significant development, speech, and hygiene problems; upon removal they tested positive for cocaine and required extensive therapy.
Psychological evaluations of the parents showed cognitive limitations and mental health issues; both admitted drug use and poor parenting history.
The trial court terminated parental rights on grounds 161.001(D) and (E), finding endangerment and conduct endangering the children, plus a finding in the best interests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legal sufficiency of the endangerment findings	Parents knowingly placed/allowed endangering conditions	State failed to prove endangerment beyond mere neglect	legally sufficient to support 161.001(D)
Factual sufficiency of the endangerment findings	Evidence showed ongoing neglect and dangerous conditions	Some evidence suggested partial improvement and compliance with services	factually sufficient to support 161.001(D)
Endangerment via conduct or placement with others	Drug use, panhandling with children, and exposure to others engaged in dangerous conduct	Parents attempted some cleanup and engaged in services; credibility determinations reserved	legally and factually sufficient to support 161.001(E)
Best interests of the children	Termination serves children's needs and stability given a proven endangerment	Preservation of parental rights preferred; foster care less optimal	clear and convincing evidence supports termination as in the children's best interests
Necessity of reviewing out-of-state termination	West Virginia termination supports Texas termination under §161.001(M)	Jury trial rights and notice issues unresolved; record otherwise adequate	unnecessary to review; one Texas ground plus best interests suffices for termination

In re J.O.A., 283 S.W.3d 336 (Tex. 2009) (clear and convincing standard applies in termination review)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (consideration of Holley factors; sufficiency standards)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (bench-review standards; evidence in light of favorable view to finding)
In re C.L.C., 119 S.W.3d 382 (Tex. App.-Tyler 2003) (endangerment and related grounds; factual/legal sufficiency discussions)
In re A.V., 113 S.W.3d 355 (Tex. 2003) (one predicate ground plus best interests suffices for termination)
In re R.R., 209 S.W.3d 112 (Tex. 2006) (presumption in best interests; Holley factors reference)