in the Interest of E.C. and A.O., Children, 07-21-00204-CV

DFPS had involvement with the family since 2013 after domestic-violence reports; a 2019 order named DFPS permanent managing conservator, later a 2020 settlement planned transfer to maternal grandparents.
Mother took the children before the settlement was court-approved; on Sept. 1, 2020, AO was struck by a vehicle while unsupervised and seriously injured; DFPS then filed to terminate both parents’ rights.
Father (EO) had a lengthy violent criminal history including convictions/arrests for child endangerment, assault/strangulation, burglary and parole violations; he had missed visitations, failed to complete services, and at trial had been absent from the children for months and had an outstanding warrant.
Father admitted he had no concrete plan to care for the children if he were arrested or returned to prison, had avoided arrest by staying in Oklahoma, and acknowledged he could have done more to complete services.
The children were placed in a foster home receiving therapy and mental-health services; foster parents intended to adopt; AO reported she felt safe in the foster home.
The trial court terminated both parents’ rights (finding grounds under Tex. Fam. Code § 161.001(b)(1)(E), (N), (O)); mother did not appeal; father appealed, challenging sufficiency of the predicate grounds and best-interest finding; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for statutory grounds (§161.001(b)(1)(E))	DFPS: father’s violent criminal history, absences, failure to complete services, drug use around children, risk of imprisonment and outstanding warrant endangered the children	EO: evidence insufficient; some evidence was stale or predated prior orders and should not support termination	Court: Evidence was clear-and-convincing for (E); appellate court affirmed that one statutory ground was sufficiently proven, relieving need to analyze others
Sufficiency of evidence that termination was in children’s best interest	DFPS: Holley factors favor termination — instability from father’s behavior, foster placement stable and children thriving	EO: termination not in children’s best interest given his asserted improvements and request for conservatorship while he reforms	Court: Holley factors supported best-interest finding (stable foster placement, children safe, father lacked plan); affirmed
Admissibility/weight of prior misconduct (allegedly "stale" evidence)	DFPS: prior convictions and conduct are relevant to endangerment and stability analysis	EO: argued appellate consideration of preexisting criminal conduct was improper/stale	Court: EO waived the issue by failing to object at trial; also rejected the stale-evidence argument on the merits in light of relevance to endangerment

In re J.F.-G., 627 S.W.3d 304 (Tex. 2021) (standard for appellate review in parental-termination cases)
In re A.V., 113 S.W.3d 355 (Tex. 2003) (only one statutory ground needed plus best interest to support termination)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (nonexclusive factors for determining child’s best interest)
Jordan v. Dossey, 325 S.W.3d 700 (Tex. App.—Houston [1st Dist.] 2010) (parental violence can create an endangering environment)
In re A.R.M., 593 S.W.3d 358 (Tex. App.—Dallas 2018) (instability from missed visitations, violence, substance use can support endangerment)
In re A.A.M., 464 S.W.3d 421 (Tex. App.—Houston [1st Dist.] 2015) (failure to object to trial evidence waives appellate complaint about its consideration)
McGee v. State, 342 S.W.3d 245 (Tex. App.—Amarillo 2011) (argument without record citation or authority is waived)