in the Interest of A.L.H., Child, 468 S.W.3d 738

Mother appeals the termination of her parental rights; affidavit of voluntary relinquishment admitted at hearing.
Court affirmed termination as to mother; father appeals termination as to him and the trial court found two bases: D endangerment and N constructive abandonment.
Department argued termination supported by evidence and reasonable efforts; no plan was created for the father.
Record shows department relied on lack of contact and paternal responsibility; father did not participate in hearings or establish paternity.
Court found department failed to prove reasonable efforts to return child to father, and evidence did not establish endangerment under D.
Court rendered judgment: terminate mother’s rights affirmed; terminate father’s rights reversed and rendered in part, with Department named sole managing conservator affirmed for child.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voluntariness of relinquishment affidavit	Mother argues involuntariness.	Department asserts compliance with §161.103 creates prima facie validity.	Affidavit valid; no evidence of fraud, duress, or coercion.
Best interests supporting termination (Mother)	Affidavit itself supports best interest.	Department’s caseworker testimony supports best interest.	Record supports termination as to mother.
Constructive abandonment (N) – reasonable efforts	Department failed to make reasonable efforts to return child to father.	Attempts to serve and paternity establishment suffice.	Evidence legally insufficient to prove N; reversal on this ground.
Endangerment (D) – knowledge of dangerous environment	Father knowingly placed child in endangering environment.	No evidence father knew of endangering conditions pre-removal.	Evidence legally insufficient to prove D; dismissal of D as a basis.
Managing conservatorship	Department should be sole managing conservator.	Termination not required for managing conservator arrangement.	Court’s managing conservatorship ruling affirmed; remaining issues resolved.

In re D.R.L.M., 84 S.W.3d 281 (Tex. App.—Fort Worth 2002) (prima facie validity of relinquishment affidavit when properly executed)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (clear standards for legal sufficiency in termination cases; heightened review)
In re J.O.A., 283 S.W.3d 336 (Tex. 2009) (burden of proof in termination actions; standards of review)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (standard for reviewing termination findings; benefit of the doubt to factfinder)