in the Interest of B.C., a Child, 06-21-00061-CV

Department filed to terminate Mother’s parental rights to her eight-year-old son, Brandon; bench trial resulted in termination on statutory grounds (including endangerment and failure to comply with court-ordered services) and a best-interest finding.
Evidence showed Mother’s longstanding methamphetamine addiction, prior loss of custody of other children, and that Brandon had previously been removed due to her drug use.
Brandon was found in a hotel room with strangers using drugs and syringes; he exhibited academic delay, frequent absences, behavioral problems, and sexualized behavior at school; he had witnessed domestic violence.
Mother failed to complete court-ordered services (in‑patient treatment, parenting classes, counseling), missed many drug tests and tested positive multiple times, and admitted using methamphetamine the day before trial; she was unstable, homeless or in transient housing, and had minimal contact/visits with Brandon.
Father had custody during the case, provided a stable home where Brandon was doing better; CASA and the Department recommended termination of Mother’s rights and appointment of Father as sole managing conservator.

Issue	Department's Argument	Mother’s Argument	Held
Whether termination of Mother’s parental rights was in the child’s best interest (factual-sufficiency challenge)	Evidence (Mother’s persistent drug use, unsafe living conditions, failure to complete services, poor parenting history, and child’s improvement with Father) supports termination under Holley factors	Termination is not in child’s best interest because Mother and child share a bond; she cited lack of transportation and COVID-19 as reasons for noncompletion of services and argued for preservation of parental rights	Court affirmed: viewing Holley factors and entire record, evidence was factually sufficient under the clear-and-convincing standard to find termination was in Brandon’s best interest

Troxel v. Granville, 530 U.S. 57 (U.S. 2000) (parental custody decisions implicate fundamental parental rights)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (enumerates best-interest factors)
Holick v. Smith, 685 S.W.2d 18 (Tex. 1985) (termination statutes strictly construed in favor of parent)
In re A.B., 437 S.W.3d 498 (Tex. 2014) (requires exacting review and clear-and-convincing proof for termination)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (evidence supporting statutory grounds may be considered in best-interest analysis)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (framework for reviewing factual sufficiency under clear-and-convincing standard)
In re J.O.A., 283 S.W.3d 336 (Tex. 2009) (defines clear-and-convincing evidence standard)