in the Interest of C.S. III, a Child, 07-17-00062-CV

Child C.S. born Aug. 2015 premature with neonatal sepsis and other complications; mother tested positive for drugs and abandoned him; father (Appellant) was incarcerated at birth and released June 2016 on supervised release.
Department filed to terminate parental rights in Nov. 2015; trial court adopted service plans requiring psychological evaluation, drug testing, counseling, stable housing/employment, medical involvement, parenting classes, and NA/AA participation.
After release Appellant attended only five two-hour visits (total ~10 hours), missed many scheduled visits, changed residences multiple times, had unstable romantic relationships, and failed to complete most service-plan requirements (psych eval delayed, no drug/alcohol assessment, no consistent proof of employment/housing, limited medical involvement).
C.S. placed in licensed foster home July 2016, where he received medical care, showed developmental progress, and the foster family planned to adopt.
Trial court found clear and convincing evidence supporting termination under Tex. Fam. Code §161.001(b)(1)(N) and (O) and also found termination was in the child’s best interest; Appellant appealed only the sufficiency of the best-interest finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was legally and factually sufficient to support termination as being in child’s best interest	Department: totality of evidence (failure to remedy conditions, unstable housing/relationships, limited visitation, lack of medical involvement, foster placement stability) supports best-interest finding	Appellant: not at fault for initial removal, drug-free, employed, obtained housing, family support, plans for daycare and parenting classes—so termination not in child’s best interest	Court affirmed: clear and convincing evidence supported best-interest finding; Holley factors weighed against Appellant (instability, lack of bonding, failure to follow service plan, inadequate medical involvement)

Santosky v. Kramer, 455 U.S. 745 (1982) (parents’ rights have constitutional dimension and heightened proof required)
Holick v. Smith, 685 S.W.2d 18 (Tex. 1985) (parental rights are fundamental but not absolute)
In re E.R., 385 S.W.3d 552 (Tex. 2012) (termination proceedings strictly construed in favor of parent but clear-and-convincing standard applies)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (statutory grounds and best-interest elements are distinct; Holley factors applicable)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (list of factors to determine child’s best interest)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (clarifies clear-and-convincing legal- and factual-sufficiency review in termination cases)
In re K.M.L., 443 S.W.3d 101 (Tex. 2014) (standards for sufficiency review of best-interest findings)