in the Interest of J.F., J.L., and J.N., Children, 06-15-00033-CV

DeDe’s longstanding drug use, criminal history, and domestic-violence exposure culminated in the Department’s removal of her five children in July 2014.
A temporary managing conservatorship granted to DFPS with DeDe as temporary possessory conservator and ordered specific reunification actions.
The Department cabinet of services required DeDe to complete a drug-alcohol assessment, counseling, parenting classes, domestic-violence programs, drug testing, abstain from drugs, and maintain stable housing and income; attendance at treatment programs was also mandated.
By trial, DeDe had not completed the required assessments, many services, or ongoing drug testing, and she remained incarcerated for parts of the period after removal.
Children were placed with paternal relatives (grandfather, grandmother, great-grandmother, etc.), with continued visitation and regular contact among siblings and extended family.
Various witnesses (caseworkers, CASA, and relatives) testified that the children were thriving in placement, bonded with caregivers, but concerns persisted about DeDe’s ability to provide stability and her propensity for drug use and criminal activity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supports termination under §161.001(b)(1)(E)	Dee’s conduct and omissions endangered children’s well-being.	Prior protective history and attempts to reform show potential for reunification; endangerment not shown.	Yes, sufficient evidence supports endangerment under E.
Whether termination is in the children's best interests	Termination would best serve stability and future adoption prospects.	Preservation of parental rights with continued services could benefit children.	Yes, termination is in the best interests of the children.

In re O.R.F., 417 S.W.3d 24 (Tex. App.—Texarkana 2013) (standard for reviewing termination and the one-predicate-rule framework)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (clear and convincing standard and sufficiency review guidance)
In re A.V., 113 S.W.3d 355 (Tex. 2003) (parental rights are not absolute; child’s best interests prevail)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (Holley framework for best-interest considerations)
N.S.G. v. Texas Department of Protective and Regulatory Services, 235 S.W.3d 358 (Tex. App.—Texarkana 2007) (endangerment standard under §161.001(b)(1)(E))
In re J.L.B., 349 S.W.3d 836 (Tex. App.—Texarkana 2011) (evidence of drug use and its impact on parenting as endangering conduct)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (Holley factors for best-interest determination)
In re A.T., 2015 WL 733275 (Tex. App.—Texarkana 2015) (Holley factors and sufficiency in Holley-contexts)
In re K.W., 335 S.W.3d 767 (Tex. App.—Texarkana 2011) (non-exhaustive Holley-factor analysis)