in the Interest of J.N.G., a Child, 14-15-00389-CV

Jane was born November 12, 2003; department received abuse report in 2008 and learned of appellant's psychiatric issues and noncompliance with medication.
Appellant admitted prior drug use and intermittent medication adherence; a safety plan placed Jane with maternal grandmother and limited contact with appellant.
In 2009, appellant attempted to strangle Jane during a dissociative episode, leading to temporary conservatorship by Department.
Jane remained in foster care from December 2009, visits with appellant ceased by 2010, and Jane’s therapist recommended no contact.
Department filed an original petition for protection and termination in 2013, amended to seek termination under multiple sections of Texas Family Code and best interest.
Jury found grounds for termination based on endangerment under §161.001(1)(E) and termination as in Jane’s best interest; trial court granted termination and appointed DFPS as sole managing conservator.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove endangerment under 161.001(1)(E)	P.N.P. argues evidence insufficient	Department argues evidence shows endangering conduct	legally and factually sufficient to support endangerment finding

In re J.O.A., 283 S.W.3d 336 (Tex. 2009) (heightened standard; endangering conduct can occur before birth; clear and convincing standard)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (clear and convincing standard; factual sufficiency framework)
In re A.V., 113 S.W.3d 355 (Tex. 2003) (one valid predicate suffices if best interest shown)
In re T.N., 180 S.W.3d 376 (Tex. App.—Amarillo 2005) (endangerment defined; conduct need not be directed at child)
In re S.M.L., 171 S.W.3d 472 (Tex. App.—Houston [14th Dist.] 2005) (endangering conduct may be inferred from parental misconduct)