in the Interest of J.G., a Child, 02-21-00020-CV

Joshua (born Apr. 2018) was removed after allegations that his mother sexually abused her teen son Justin and after the household showed neglect and unsafe conditions.
Father knew or suspected the abuse but delayed reporting and made a second 911 call that downplayed the conduct; he also continued contact with Mother after removal and sent her videos of Joshua.
Father attempted suicide twice while the children were in the home, had significant alcohol and anger issues (punched Justin, damaged walls), and the home and children showed poor hygiene and unsafe conditions.
The three youngest children (including Joshua) were placed together in foster care with the Fosters; Joshua became bonded to the foster family and made developmental progress there.
Trial court found clear-and-convincing evidence of statutory endangerment and that termination of Father’s parental rights was in Joshua’s best interest; Father appealed only the best-interest sufficiency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was legally and factually sufficient to support that termination was in Joshua’s best interest	Dept.: Father’s failure to protect (delay reporting sexual abuse), suicide attempts, alcohol/violence, unsafe home, continued contact with Mother, and child’s progress in foster care support termination	Father: He completed most services, is employed, has housing, visits showed bonding, and can meet Joshua’s needs — insufficient to terminate	Affirmed. Considering endangerment, risk of future harm, lack of protective capacity, and foster placement, evidence was legally and factually sufficient to find termination in child’s best interest
Whether trial court could/should have instead named Dept. permanent managing conservator and left Father possessory rights	(Dept. implication) permanency via termination was appropriate because Father’s pattern made future protection unlikely	Father: Court could have given Dept. PMC and allowed him more time as possessory conservator	Court treated this challenge as inadequately briefed and noted the record did not support denying termination and awarding PMC under statutory scheme

In re E.N.C., 384 S.W.3d 796 (Tex. 2012) (clear-and-convincing proof and best-interest requirement for termination)
In re J.L., 163 S.W.3d 79 (Tex. 2005) (termination statutory elements and best-interest review)
In re J.P.B., 180 S.W.3d 570 (Tex. 2005) (standard for legal sufficiency in parental-termination cases)
In re J.O.A., 283 S.W.3d 336 (Tex. 2009) (factfinder’s role in weighing credibility)
In re A.B., 437 S.W.3d 498 (Tex. 2014) (requirement for exacting factual-sufficiency review)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (Holley factors and that one factor can be dispositive)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (nonexclusive best-interest factors for child custody)
In re E.C.R., 402 S.W.3d 239 (Tex. 2013) (evidence probative of statutory grounds can also support best-interest finding)
In re A.C., 560 S.W.3d 624 (Tex. 2018) (child-centered best-interest analysis focusing on safety and development)