in the Interest of G.R., M.R., A.R., A.R., Children, 07-16-00277-CV

Mother B.R.’s four children were removed after police found toddlers unattended, the home in disrepair, and a child with access to a loaded handgun; officers observed B.R. appearing under the influence.
The Department had previously opened two cases concerning B.R. (domestic violence and drug use) that were closed when she could not be located.
B.R. received a court-ordered service plan and completed many but not all tasks: she failed domestic-violence services, failed two drug screens, and was discharged from therapy as not ready for further treatment.
During the ~18-month case B.R. lacked stable housing and steady employment and admitted continued drug use after removal; she also remained in or returned to an abusive relationship.
The children improved behaviorally in foster care; their behavior regressed after visits with B.R. and improved when visitation was suspended.
The trial court terminated B.R.’s parental rights under Texas Family Code § 161.001(b)(1)(D), (E), and (O), and found termination was in the children’s best interest; B.R. appeals only the sufficiency of evidence as to (O) and best interest.

Issue	Plaintiff's Argument (B.R.)	Defendant's Argument (Department)	Held
Sufficiency of evidence for §161.001(b)(1)(O) (failure to comply with court-ordered service plan)	Evidence was legally and factually insufficient to show B.R. failed to complete her service plan as required.	Unchallenged findings under (D) and (E) are binding; record shows B.R. did not complete all ordered services (domestic violence, drug screens) and lacked stability.	Court declined to reach (O) sufficiency because B.R. did not challenge (D) and (E); those unchallenged predicate findings are sufficient to support termination when best interest is shown.
Sufficiency of evidence that termination is in children’s best interest (§161.001(b)(2))	Evidence did not satisfy clear-and-convincing standard to show termination served children’s best interest.	Evidence of hazardous conditions, continued drug use, instability, negative impact on children after visits, and foster-placement improvement support best-interest finding under Holley factors.	Court held evidence legally and factually sufficient; termination is in the children’s best interest.

Holick v. Smith, 685 S.W.2d 18 (Tex. 1985) (parental rights have constitutional dimensions and termination decrees are final)
Santosky v. Kramer, 455 U.S. 745 (U.S. 1982) (due process requires strict scrutiny in parental-termination cases)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (clear-and-convincing standard and review methodology for legal sufficiency in termination cases)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (factual-sufficiency standard and Holley-factor discussion)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (non-exhaustive factors for determining a child’s best interest)
In re A.V., 113 S.W.3d 355 (Tex. 2003) (only one statutory ground required to support termination)