in the Interest of L.C.L. and M.E.M., Children, 599 S.W.3d 79

After a bench trial the trial court found termination of Mother’s parental rights was in the children’s best interest; Mother appealed alleging both legal and factual insufficiency of the best-interest findings.
The en banc court concluded the evidence was legally sufficient but factually insufficient to support the best‑interest findings.
This text is Chief Justice Frost’s en banc dissent criticizing the en banc majority for reversing on factual‑insufficiency grounds without the detailed, particularized analysis required by Texas precedent and Rule 47.4.
The dissent emphasizes governing law that requires an appellate court, when finding factual insufficiency in parental‑termination cases, to identify disputed evidence, explain why a reasonable factfinder could not credit it, and show why that uncreditable evidence is so significant that a factfinder could not have formed a firm belief.
The dissent argues the majority’s opinion contains no identification or analysis of disputed evidence, fails to ‘‘show its work,’’ and thus violates Supreme Court precedent (e.g., In re J.F.C., Windrum) and undermines transparency, stare decisis, and appellate review.
En banc composition: Majority opinion authored by Justice Hassan (joined by Justices Bourliot, Zimmerer, Spain, Poissant); dissenting opinions by Justice Wise and Chief Justice Frost (joined by other justices as noted).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legal sufficiency of best‑interest findings	Mother: evidence fails even under legal‑sufficiency standard	State/Trial court: evidence meets legal sufficiency	En banc majority: evidence is legally sufficient
Factual sufficiency of best‑interest findings	Mother: evidence is factually insufficient under clear‑and‑convincing standard	State: reasonable factfinder could have formed firm belief; evidence supports findings	En banc majority: evidence is factually insufficient; dissent: majority failed to detail analysis required for such a conclusion
Required detail in factual‑sufficiency opinions	Mother: (implicitly) appellate court must explain its factual‑sufficiency reasoning	State: (implicitly) appellate review can affirm or reverse if standards met; must follow precedent	Dissent: appellate courts must identify disputed evidence and explain why it could not be credited and why remaining evidence is insufficient; majority did not do so
Effect of failing to ‘‘show work’’ on appellate process	Mother: absence of analysis harms parties' understanding and reviewability	State/majority: reached a result but did not provide required explanatory detail	Dissent: failure to explain undermines transparency, Supreme Court review, and precedent; reversal without analysis is improper

In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (sets clear‑and‑convincing standard and factual‑sufficiency framework for parental‑termination reviews)
Windrum v. Kareh, 581 S.W.3d 761 (Tex. 2019) (explains high hurdle for factual‑sufficiency reversals and need for particularized analysis)
In re Columbia Medical Center of Las Colinas, Subsidiary, L.P., 290 S.W.3d 204 (Tex. 2009) (appellate opinions must explain analyses and conclusions)
Gonzalez v. McAllen Medical Center, Inc., 195 S.W.3d 680 (Tex. 2006) (per curiam) (Rule 47.4 and the requirement that opinions provide reasons)
Pool v. Ford Motor Co., 715 S.W.2d 629 (Tex. 1986) (requires appellate courts to give reasons to permit review of the analytical process)
Golden Eagle Archery, Inc. v. Jackson, 116 S.W.3d 757 (Tex. 2003) (addresses standards for sufficiency review and appellate explanation)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (addresses limits on appellate courts substituting their judgment for the factfinder)
Bocquet v. Herring, 972 S.W.2d 19 (Tex. 1998) (discusses appellate obligations in explaining reversals)