in the Interest of E.A.T. Jr. and E.A.T., Children, 04-21-00440-CV

Department investigated alleged drug use and physical abuse; when officers attempted removal Dad barricaded himself inside with the children.
Dad has an extensive criminal history including domestic violence, admitted methamphetamine use, and tested positive on a court-ordered follicle test six months before trial.
Dad engaged in counseling briefly and entered residential treatment but was later rearrested, failed to maintain contact with his caseworker, completed no further services while jailed, and had unresolved charges with no release date.
Visits with Dad corresponded with significant behavioral and emotional problems in son E.A.T. Jr., leading to a specialty therapeutic placement; by trial both children were placed together and were doing well and preferred their current caregiver.
CASA, the caseworker, and the children’s attorney ad litem recommended termination; the trial court found statutory grounds under Tex. Fam. Code §161.001(b)(1) (D), (E), (N), and (O) and, by clear and convincing evidence, that termination was in the children’s best interests; the Fourth Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was legally and factually sufficient to show termination was in the children’s best interests	Dad argued the evidence was legally and factually insufficient to support termination	Department/CASA/ad litem relied on Dad’s domestic violence, drug relapse, criminal instability, children’s improved and stable placement, and child’s adverse reactions to visits	Affirmed — evidence was legally and factually sufficient to form a firm belief or conviction that termination was in the children’s best interests
Whether Dad was entitled to more time to reunify	Dad requested additional time to complete services and regain custody	Trial court noted the case had been open too long, Dad’s incarceration and unresolved charges, and inability to complete services justified refusing extension	Court treated request and timing as part of best-interest analysis; no reversal — no extension available under circumstances

Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (nonexclusive best-interest factors)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (legal and factual sufficiency standard for termination cases)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (clear-and-convincing evidence and appellate review standards)
In re J.L., 163 S.W.3d 79 (Tex. 2005) (definition of "firm belief or conviction" standard)
In re H.R.M., 209 S.W.3d 105 (Tex. 2006) (applying clear-and-convincing review in parental-termination context)
In re A.C., 560 S.W.3d 624 (Tex. 2018) (recognition of statutory best-interest factors)
In re N.J.H., 575 S.W.3d 822 (Tex. App.—Houston [1st Dist.] 2018) (relevance of parent drug history to future risk to child)