in the Interest of G.G.C. AKA G.C.G., E.G.C., R.D.G.C. AKA R.G.C., K.S.G.M. AKA K.G.M., K.M.G.M AKA K.G.M. and K.E.G.M. AKA K.G.M., Children, 01-16-00891-CV

Mother E.N.G., 26, has six children under ten; DFPS previously took temporary conservatorship after a 2012 incident where a toddler ingested cocaine and the mother forcibly removed him from the hospital (criminal conviction for child endangerment; later jailed for probation violations).
DFPS investigated multiple subsequent referrals (2015) alleging drug use/sales from home, neglectful supervision, poor home conditions, hygiene issues, and sexualized behavior by some children.
DFPS found the apartment in deplorable condition; mother tested positive for marijuana (May 2015) and for cocaine multiple times (Oct–Dec 2015); she refused many offered services and did not complete the court-ordered family-service plan.
In Oct 2015 the trial court removed the children and incorporated a service plan; DFPS filed to terminate mother’s parental rights for noncompliance and endangerment.
At bench trial DFPS presented evidence of drug use/sale, prior convictions, unstable home, and children doing well in foster placements; trial court terminated mother’s parental rights and found statutory grounds under Tex. Fam. Code §161.001(1), and that termination was in children’s best interest.

Issue	Plaintiff's Argument (E.N.G.)	Defendant's Argument (DFPS)	Held
Whether evidence supports termination under §161.001(1)(E) (endangerment)	Mother argued evidence was legally and factually insufficient to prove endangerment	DFPS relied on mother’s drug use/sales, prior child-endangerment conviction, arrests/imprisonment, and unsafe home conditions	Court held evidence was legally and factually sufficient to find endangerment
Whether termination supported by other statutory grounds (§161.001(1)(L),(O))	Mother challenged sufficiency of remaining grounds	DFPS alleged failure to comply with service plan and other statutory predicates	Court did not need to reach remaining grounds after affirming endangerment finding
Whether termination is in children’s best interest under §161.001(2)	Mother argued termination was not in children’s best interest; proposed placement with father	DFPS presented children’s stable, long-term foster placements, mother’s ongoing substance use, failure to complete services, and prior dangerous conduct	Court held evidence was legally and factually sufficient to find termination was in children’s best interest
Standard of proof on appeal (legal/factual sufficiency)	Mother argued appellate review should overturn for insufficiency	DFPS urged deferential review to factfinder with clear-and-convincing standard applied to record	Court applied legal- and factual-sufficiency standards for clear-and-convincing evidence and affirmed

Santosky v. Kramer, 455 U.S. 745 (establishes clear-and-convincing standard for parental termination)
Holick v. Smith, 685 S.W.2d 18 (Tex. 1985) (parental-rights termination subject to strict scrutiny and clear-and-convincing proof)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (standards for legal and factual sufficiency review in termination cases)
Tex. Dep’t of Human Servs. v. Boyd, 727 S.W.2d 531 (discusses meaning of "endanger")
In re J.O.A., 283 S.W.3d 336 (Tex. 2009) (drug abuse as evidence of endangering conduct)
Walker v. 312 S.W.3d 617 (discusses imprisonment and endangerment in parental-rights cases)
In re A.V., 113 S.W.3d 355 (one predicate finding plus best interest suffices for termination)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (Holley factors for best-interest analysis)
In re C.H., 89 S.W.3d 17 (standards that State need not prove every Holley factor)