in the Interest of M.D., a Child, 07-21-00149-CV

G.D., the biological father, appealed the trial court’s involuntary termination of his parental rights to M.D.; he contested only the best-interest prong on appeal.
M.D. was born June 2018 and removed March 14, 2020 after testing positive for marijuana/THC; his mother largely failed reunification requirements and eventually abandoned the children.
G.D. was incarcerated for most of M.D.’s life (except a two-month release), never formed a bond with the child, and provided no meaningful financial or emotional support.
During the two-month release, G.D. did not complete services, submit to drug testing, or obtain employment and was subsequently reincarcerated for parole violations.
M.D. and his sibling were placed with relatives (a couple/cousins) who provided a stable, nurturing home, completed services, helped M.D. overcome developmental/speech delays, and formed strong parental bonds.
The trial court found statutory grounds for termination under Tex. Fam. Code § 161.001(b)(1)(D),(E),(F),(Q); the appellate court applied Holley factors and affirmed that termination was in the child’s best interest.

Issue	G.D.'s Argument	Respondent's Argument	Held
Whether termination of G.D.'s parental rights was in M.D.'s best interest	Evidence was insufficient to show termination was in child’s best interest	Father’s incarceration, lack of bond/support, failure to complete services, and the child’s stability and improvement with relatives support termination	Affirmed: clear-and-convincing evidence supports best-interest finding

Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (establishes non-exhaustive factors for best-interest analysis)
In re N.G., 577 S.W.3d 230 (Tex. 2019) (addresses review of predicate grounds and effect on future parental-rights consequences)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (standard for best-interest sufficiency and factors weighing termination)
In re J.P.B., 180 S.W.3d 570 (Tex. 2005) (review standard for legal sufficiency in termination cases)
In re A.B., 437 S.W.3d 498 (Tex. 2014) (requires exacting review of factual sufficiency for termination findings)
In re E.D., 419 S.W.3d 615 (Tex. App.—San Antonio 2013, pet. denied) (past conduct used to predict future parental conduct in best-interest analysis)
In re E.A.F., 424 S.W.3d 742 (Tex. App.—Houston [14th Dist.] 2014, pet. denied) (supporting authority that predicate findings can inform best-interest determination)