in the Interest of A.M.A., a Child, 07-16-00224-CV

Child A.M.A. was removed in 2012; Department named temporary managing conservator in December 2012 and permanent managing conservator in May 2014; G.A. was made possessory conservator with restricted visitation.
The May 2014 final order required G.A. to complete services (return to Texas, individual counseling, employment/housing, random drug testing, NA/AA attendance, parenting classes, OSAR), but G.A. did not begin or complete those services.
From May 2014 through late 2015 G.A. was incarcerated for substantial periods and had multiple drug-related convictions and pending charges; Department presented judgments and testimony of continued substance abuse.
G.A. had virtually no contact with A.M.A. after the permanent-conservatorship order; the caseworker testified G.A. never inquired about the child during limited contacts and did not pursue supervised visitation opportunities.
A.M.A. had lived with foster parents nearly three years, was bonded to them, referred to them as "mom" and "dad," and expressed a desire for adoption; the foster parents planned to adopt.
The trial court terminated G.A.’s parental rights under Tex. Fam. Code §161.001(b)(1)(D), (E), (N), and (O) after a bench trial; G.A. appealed, challenging factual and legal sufficiency but not the best-interest finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clear-and-convincing evidence supports termination under §161.001(b)(1)(E) (endangering conduct)	G.A.’s ongoing drug abuse, convictions, incarceration, failure to complete services, and lack of contact endangered the child	Evidence factually and legally insufficient to show endangerment	Held: Sufficient — court affirmed termination on subsection (E) ground
Whether any statutory ground supports termination when multiple grounds were alleged	Any single proved statutory ground suffices; Dept. relied on (E) among others	G.A. challenged sufficiency of evidence for the grounds	Held: Only one ground required; (E) proved, so termination stands
Whether termination was in the child’s best interest	Dept.: termination serves child’s stability and adoption plan	G.A.: did not contest best-interest finding on appeal	Held: Trial court found best interest; finding not contested and supports affirmation
Standard of review for sufficiency challenges (legal/factual)	Clear-and-convincing standard; defer to factfinder when reasonable	G.A. argued the evidence could not support a firm belief by the trier of fact	Held: Applying the clear-and-convincing legal and factual-sufficiency standards, evidence permitted a firm belief in endangerment; issues overruled

Holick v. Smith, 685 S.W.2d 18 (Tex. 1985) (parental rights are constitutional but subject to strict scrutiny)
Santosky v. Kramer, 455 U.S. 745 (U.S. 1982) (due process requires high standard for involuntary termination)
In re G.M., 596 S.W.2d 846 (Tex. 1980) (termination proceedings receive strict judicial scrutiny)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (statutory grounds and best-interest elements are distinct; parental rights are not absolute)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (clear-and-convincing standard explained; legal/factual sufficiency review guidance)
In re A.V., 113 S.W.3d 355 (Tex. 2003) (proof of a single statutory ground is sufficient for termination if best interest is shown)
In re M.C., 917 S.W.2d 268 (Tex. 1996) (definition of endanger and scope of endangering conduct)
In re A.W.T., 61 S.W.3d 87 (Tex. App.—Amarillo 2001) (incarceration and criminal activity are relevant to endangerment)