in the Interest of K.A.A., a Child, 07-21-00296-CV

Mother admitted a long-term methamphetamine addiction, including use while pregnant with K.A.A.; two older children live with their father due to her addiction.
K.A.A. tested positive for methamphetamine; child was removed in May 2020 and placed with a foster family in August 2020 that is stable and willing to adopt.
Mother initially completed some services (rational behavior training, psychosocial evaluation, NA meetings) but failed to complete required substance-abuse programs, counseling, employment stability, and OSAR assessment.
Mother tested positive for methamphetamine multiple times in 2021, had inconsistent visitation (missed several recent visits), and maintained contact with a meth-using paramour.
Trial court found statutory predicate grounds for termination under Texas Family Code §161.001(b)(1)(D), (E), and (O) and concluded termination was in the child’s best interest; Mother appealed only the best-interest finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clear-and-convincing evidence supports that termination is in child’s best interest	Mother: evidence is legally and factually insufficient to show termination serves K.A.A.’s best interest	Department: mother’s ongoing addiction, positive drug tests, failure to complete plan, unstable housing/contacts, and child’s stable foster placement support best-interest finding	Court: Affirmed — evidence legally and factually sufficient to support best-interest finding

In re E.N.C., 384 S.W.3d 796 (Tex. 2012) (requiring clear-and-convincing standard in termination cases)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (standards for reviewing termination evidence)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (enumerating factors for best-interest analysis)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (one Holley factor can suffice when evidence shows endangerment)
In re R.R., 209 S.W.3d 112 (Tex. 2006) (discussing presumption favoring keeping child with parent and factors for best interest)