in the Interest of A.F.C., I.C.C., A.R.H., Jr., Children, 04-17-00080-CV

Mother’s three children were removed after Department referral alleging Mother’s methamphetamine use, domestic violence, and mental-health issues; two girls placed in foster care, infant son placed with paternal grandmother.
The Department adopted a court-ordered service plan requiring counseling, parenting classes, mental-health evaluation, and outpatient substance-abuse treatment; Mother failed to complete required services and tested positive for methamphetamine multiple times.
Mother was incarcerated twice during the case (assault allegations and probation violation); she admitted hearing voices and having suicidal ideation but did not obtain ordered mental-health evaluation or complete treatment.
Therapists suspended parent-child visits due to concerns about Mother’s lifestyle; children (especially the older girls) have special needs and made significant progress in care after removal.
The Department sought termination under Tex. Fam. Code §161.001(b)(1)(D),(E),(O),(P) and (b)(2); trial court terminated Mother’s parental rights as being in the children’s best interests; Mother appealed only the best-interest finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was legally and factually sufficient to find termination was in children’s best interests	Mother argued the Department presented limited evidence on Holley factors (children’s desires, programs, parental abilities) so best-interest finding was unsupported	Department argued cumulative evidence (endangerment, substance abuse, domestic violence, failure to complete services, children’s progress in placements) supported a firm belief termination served children’s best interests	Court held evidence was legally and factually sufficient; affirmed termination

In re J.F.C., 96 S.W.3d 256 (establishes standard for clear-and-convincing sufficiency review in termination cases)
In re C.H., 89 S.W.3d 17 (courts need not find every Holley factor; parental endangerment probative of best interest)
Holley v. Adams, 544 S.W.2d 367 (lists factors for best-interest analysis)
In re R.R., 209 S.W.3d 112 (presumption that maintaining parent–child relationship is in child’s best interest)
In re B.R., 456 S.W.3d 612 (circumstantial and totality-of-evidence consideration in best-interest analysis)
In re J.P.B., 180 S.W.3d 570 (deference to factfinder on credibility and demeanor)
In re J.D., 436 S.W.3d 105 (consideration of young child’s bonding with caregivers when child cannot express desires)
In re J.I.T.P., 99 S.W.3d 841 (domestic violence as evidence of endangerment)
In re W.E.C., 110 S.W.3d 231 (failure to use available services supports finding lack of motivation to improve parenting)
In re D.J.H., 381 S.W.3d 606 (instability and uncertainty as endangering conduct)