in the Interest of E.L., a Child, 02-17-00247-CV

Mother (B.L.) appealed the trial court’s final order terminating her parental rights to E.L.; termination was based on multiple statutory grounds under Tex. Fam. Code § 161.001(b)(1) and the court found termination was in the child’s best interest under § 161.001(b)(2).
Mother did not appear at trial but was represented by counsel; counsel presented evidence and cross-examined witnesses at trial.
Mother’s appellate counsel filed an Anders-style brief and a motion to withdraw, concluding no non-frivolous issues existed for appeal and notifying Mother of her rights; the Department declined to respond to the motion to withdraw.
The court attempted to notify Mother by mail and phone; mailings were returned undeliverable and phone calls were not returned; Mother did not file a response to the Anders brief.
The Court of Appeals conducted an independent review of the record, concluded the evidence legally and factually supported at least one statutory ground and best-interest finding, and affirmed the termination.
The court denied appellate counsel’s motion to withdraw without prejudice as premature.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for statutory grounds under § 161.001(b)(1)	Trial evidence did not support termination on all alleged subsections; some grounds arguable weak	Court: evidence supported at least one alleged statutory ground (other than possibly (P))	Affirmed — record supports at least one statutory ground proved by clear and convincing evidence
Best interest of the child under § 161.001(b)(2)	Termination was not in E.L.’s best interest	Court: evidence supported the trial court’s best-interest finding based on credibility and weight of evidence	Affirmed — termination is in child’s best interest
Adequacy of Anders brief and counsel’s request to withdraw	Counsel argued appeal was frivolous and sought to withdraw under Anders/Kelly procedures	Department declined to oppose; Mother did not respond or contest adequacy	Court independently reviewed record, agreed no arguable grounds; affirmed judgment but denied counsel’s motion to withdraw without prejudice as premature
Notice/ability to participate on appeal	Mother could claim lack of effective notice or opportunity to respond	Record shows counsel provided Anders brief, court attempted to notify Mother by mail/phone, Mother did not respond	Court treated notice/response attempts as sufficient for Anders procedure; no reversible error shown

Anders v. California, 386 U.S. 738 (Anders procedure for counsel to move to withdraw when appeal is frivolous)
In re K.M., 98 S.W.3d 774 (applying Anders procedures in parental-termination appeals)
In re A.B., 437 S.W.3d 498 (appellate courts need not detail evidence when affirming termination)
In re H.R.M., 209 S.W.3d 105 (credibility and weight-of-evidence determinations are for the trial court)
In re P.M., 520 S.W.3d 24 (withdrawing counsel in parental-termination appeals — timing and propriety)
Kelly v. State, 436 S.W.3d 313 (procedural rules for counsel notifying client and appellate court in Anders/Kelly context)
In re S.F., 32 S.W.3d 318 (proof of any one statutory ground supports termination when multiple grounds alleged)