in the Interest of H.P. and F.P., Children, 13-16-00277-CV

In March 2015 the Texas Department of Family and Protective Services removed H.P. (age 2) and F.P. (age 8 months) after shelter staff discovered the parents injecting heroin while caring for the children and syringes accessible to them.
Initial testing showed F.P. positive for heroin; both parents admitted extensive daily heroin use and confirmed unstable housing and limited income.
The trial court ordered family service plans and court-ordered drug assessments; parents repeatedly tested positive, failed to complete court-referred substance-abuse treatment, and had intermittent incarceration and unstable housing during the case.
Parents visited consistently and behaved appropriately during visits, but medical neglect (untreated thyroid medication, respiratory infection) and ongoing drug use continued during pendency.
The Department sought termination; after a bench trial the court found multiple statutory grounds under Tex. Fam. Code § 161.001(b)(1) and that termination was in the children’s best interests under § 161.001(b)(2).
The court of appeals affirmed, holding appellants waived their challenge to termination under subsection (P) and that the evidence supported best-interest findings under the Holley factors.

Issue	Plaintiff's Argument (Department)	Defendant's Argument (Parents)	Held
1. Legal & factual sufficiency of evidence for statutory termination grounds	Parents used controlled substances in a manner endangering the children and failed to complete court-ordered treatment (§161.001(b)(1)(P)); other predicate grounds also proven	Evidence insufficient to prove any statutory ground	Court: Parents waived substantive challenge to (P) by inadequate briefing; one predicate suffices, so termination grounds stand (affirmed)
2. Legal & factual sufficiency that termination is in children’s best interests	Termination necessary due to ongoing instability, medical neglect, continued drug use, failure to complete services; Holley factors favor termination	Parents argue employment, appropriate visitation, and Father’s claimed sobriety/stated plans show best interests do not require termination	Court: Best-interest finding supported by clear-and-convincing evidence under Holley factors (affirmed)

In re K.M.L., 443 S.W.3d 101 (Tex. 2014) (clear-and-convincing standard for termination of parental rights)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (legal-sufficiency review under clear-and-convincing standard)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (factual-sufficiency review and consideration of evidence a factfinder could credit)
In re H.R.M., 209 S.W.3d 105 (Tex. 2006) (clarifies standard for forming firm belief under clear-and-convincing evidence)
In re J.O.A., 283 S.W.3d 336 (Tex. 2009) (role of disputed evidence in sufficiency review)
In re E.N.C., 384 S.W.3d 796 (Tex. 2012) (only one statutory predicate is required to support termination)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (Holley factors for best-interest analysis)
In re E.R., 385 S.W.3d 552 (Tex. 2012) (balancing parental rights against child’s best interest)
In re J.D., 436 S.W.3d 105 (Tex. App.—Houston [14th Dist.] 2014) (permanence and parental instability relevant to best-interest analysis)
In re A.C., 394 S.W.3d 633 (Tex. App.—Houston [1st Dist.] 2012) (parent’s failure to complete treatment supports termination)