in the Interest of J.M.H., 01-15-00734-CV

Mother (then 16) had an infant; child initially lived with mother and maternal grandmother; father absent from proceedings.
Department investigated after family history of sexual abuse in grandmother’s home and after mother ran away with the infant, placing the child at risk.
Mother placed the child with a cousin, but relatives forcibly attempted to recover the child; grandmother threatened to beat mother if she returned home; mother said she would run away again if forced to stay with grandmother.
Mother’s court-ordered family service plan required psychological evaluation, drug/alcohol assessment, individual counseling, and school completion; mother completed the psychological assessment (showing borderline intellectual disability, ADHD, bipolar disorder) but did not complete counseling and tested positive for drugs (marijuana, one initial cocaine-positive test she disputed).
Child was removed from home after unstable placements (cousin tested positive for marijuana; grandmother’s home previously associated with abuse and currently barred due to household risks) and placed with a foster family; foster testimony described prior coughing, cigarette smell, sleep and crying problems that improved in foster care.
Trial court terminated mother’s parental rights under Tex. Fam. Code § 161.001(1)(E) (endangerment) and (O) (failure to comply with service plan), and found termination was in the child’s best interest; mother appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for endangerment under §161.001(1)(E)	Mother argued evidence was legally and factually insufficient to show she engaged in or placed child with persons who endangered the child	Department relied on mother’s conduct, family violence/instability, drug use, and failed services to show endangerment	Court declined to reach merits because mother did not challenge the unchallenged §161.001(1)(O) finding; termination supported by at least one predicate ground
Sufficiency of evidence that termination is in child’s best interest under §161.001(2)	Mother argued termination was not supported by clear and convincing evidence of best interest	Department pointed to child’s physical/emotional improvement in foster care, family violence, mother’s drug use, failure to complete services, and repeated running away/instability	Court held evidence (Holley factors and unchallenged predicate) was legally and factually sufficient to support best-interest finding and affirmed termination

In re C.H., 89 S.W.3d 17 (Tex. 2002) (definition and standard for clear and convincing evidence in termination cases)
State v. Addington, 588 S.W.2d 569 (Tex. 1979) (standard for clear and convincing proof)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (standards for reviewing legal and factual sufficiency in parental termination appeals)
In re A.V., 113 S.W.3d 355 (Tex. 2003) (only one predicate finding under §161.001(1) is necessary when best interest is shown)
In re S.M.R., 434 S.W.3d 576 (Tex. 2014) (proof of any one ground plus best interest supports termination)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (factors for determining a child’s best interest)