In the Interest of J.K.V., 485 S.W.3d 202

Mother (Emma) checked into a shelter with her children in Nov 2013; while there, her 18‑month‑old son J.K.V. suffered head and facial injuries and Emma refused/failed to obtain medical care despite being told to do so.
Department investigator observed injuries inconsistent with Emma’s explanation, Emma tested positive for methamphetamine, and the children were removed in April 2014; investigator also saw unsafe supervision (child placing pills/baby powder in mouth) and Emma’s uncontrolled behavior.
Emma refused to engage with or sign a Department service plan, made limited visits (child showed little attachment), later left for Mexico, underwent inpatient drug rehab there, and had periods of no contact with the Department.
J.K.V. lived with the same foster family from April 2014; he improved physically and emotionally, bonded with foster parents, and the foster family sought to adopt him.
At trial, the Department sought termination of Emma’s parental rights under Texas Family Code § 161.001; the trial court terminated rights, and this appeal challenges whether evidence was factually sufficient to show termination was in the child’s best interest.

Issue	Emma’s Argument	Department’s Argument	Held
Whether evidence was factually sufficient to show termination was in child’s best interest	Emma argued she had overcome drug habit, gained employment and housing, and wanted her children; claimed improvement before hearing	Department argued Emma’s past neglect, drug use, refusal to follow services, abandonment, and the child’s bond with foster family supported termination	Court held evidence was factually sufficient to find termination in child’s best interest and affirmed judgment

In re J.F.C., 96 S.W.3d 256 (clarifies clear-and-convincing standard in parental-rights termination reviews)
In re J.O.A., 283 S.W.3d 336 (discusses burden and review of clear-and-convincing evidence)
In re C.H., 89 S.W.3d 17 (directs appellate courts to give due consideration to fact‑finder’s clear‑and‑convincing findings)
In re R.A.L., 291 S.W.3d 438 (cautions against treating clear‑and‑convincing review like beyond a reasonable doubt)
In re H.R.M., 209 S.W.3d 105 (per curiam) (addresses appellate review standards in termination cases)
In re R.R., 209 S.W.3d 112 (recognizes presumption favoring natural parent but allows overcoming it with clear-and-convincing evidence)
Holley v. Adams, 544 S.W.2d 367 (sets non‑exclusive list of best‑interest factors)
In re U.P., 105 S.W.3d 222 (considers child’s bonding with foster family in best‑interest analysis)
In re J.O.C., 47 S.W.3d 108 (explains that one or more factors can suffice to support best‑interest finding)
In re C.A.J., 122 S.W.3d 888 (considers lack of parenting skills, income, housing, and instability in best‑interest analysis)