in the Interest of A.E., 05-14-01340-CV

Mother (b.1971) had a long history of substance use, multiple arrests/incarcerations, and prior terminations of parental rights to three older children in Florida; she moved to Texas in early 2000s.
Mother gave birth to A.E. in 2008, married Husband (not A.E.’s biological father) who had criminal/parole history and tested positive for cocaine during the DFPS investigation.
In January–February 2013 events (domestic violence, Mother’s arrest for evading with unrestrained A.E., and an allegation of sexual abuse arising from an unsupervised daycare situation) led to A.E.’s removal and placement in foster care.
A.E. displayed developmental delays, anxiety, trauma indicators, fear of males, and behavioral issues upon entry to care; after placement with foster parents she made substantial cognitive, emotional, and behavioral gains.
Mother completed many court-ordered services (classes, counseling, evaluations), secured housing and employment after release from incarceration, but evaluators and DFPS witnesses emphasized Mother’s minimization of past drug use, prior pattern of abusive relationships, impulsivity, and limited candor, raising concern about future risk.
DFPS sought termination under Tex. Fam. Code §161.001(1)(D),(E),(O) and asserted termination was in A.E.’s best interest; the jury found statutory grounds and best interest proven and the trial court terminated Mother’s parental rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence is legally and factually sufficient to show termination is in child’s best interest	Mother: her testimony showed stable job, apartment, completion of services, improved parenting, bond with A.E., and A.E.’s expressed desire to return home	State/DFPS: Mother’s criminal history, prior terminations, domestic violence, dishonesty to evaluators, personality traits (impulsivity/narcissism), and children’s progress in foster care show continued risk and favor adoption	Court affirmed: evidence legally and factually sufficient to support best‑interest finding

In re M.S., 115 S.W.3d 534 (Tex. 2003) (parental interest in custody is fundamental)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (clear-and-convincing standard and appellate sufficiency review in termination cases)
In re E.N.C., 384 S.W.3d 796 (Tex. 2012) (statutory two-prong test for termination: conduct + best interest)
In re E.A.F., 424 S.W.3d 742 (Tex. App.—Houston [14th Dist.] 2014, pet. denied) (presumptions regarding natural parent and prompt permanent placement)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (parental conduct that endangers child supports best-interest finding)
In re A.B., 437 S.W.3d 498 (Tex. 2014) (heightened appellate standard of review for termination findings)
In re H.R.M., 209 S.W.3d 105 (Tex. 2006) (deference to factfinder on credibility)
In re J.P.B., 180 S.W.3d 570 (Tex. 2005) (credibility determinations owed deference on appeal)
In re A.W., 444 S.W.3d 690 (Tex. App.—Dallas 2014) (evidence of prior living conditions and foster stability can support best-interest finding)