in the Interest of N.A.C. Jr., J.A.C., and M.I.C., 04-17-00138-CV

The Texas Department of Family and Protective Services filed to terminate appellant’s parental rights to her three children in April 2016 after referrals for suspected parental drug use, neglect, and safety concerns.
Investigators found appellant and her sister tested positive for methamphetamines; appellant later had additional positive drug tests.
Children were initially placed with the paternal aunt (Barbie C.) under a safety plan; appellant received supervised visits and was offered Family Based Safety Services and substance‑abuse treatment.
Appellant failed to complete the outpatient substance‑abuse program (unsuccessful discharge for noncompliance), missed many visits and appointments, and did not follow through on medical care for one child (hearing issues).
Under the aunt’s care the children’s behavior, medical care, speech therapy, immunizations, and general functioning improved; the Department’s permanency plan was adoption by the aunt.
At the one‑day bench trial appellant did not appear; the trial court found multiple statutory grounds proven and concluded termination was in the children’s best interest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was legally and factually sufficient to show termination was in the children’s best interest under Family Code §161.001(b)(2)	The Department (State) argued appellant’s continued drug use, instability, failure to complete treatment, missed visits/appointments, inadequate housing/employment, and failure to address children’s medical needs made termination necessary for the children’s safety and permanency	Appellant argued the evidence was insufficient to support finding termination served the children’s best interest (appeal raised only best‑interest sufficiency)	Court affirmed: viewing evidence in the light most favorable to the finding, the trial court could reasonably form a firm belief termination was in the children’s best interest

Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (sets out non‑exhaustive factors to evaluate child’s best interest)
In re R.R., 209 S.W.3d 112 (Tex. 2006) (presumption that keeping a child with a parent is in the child’s best interest)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (evidence proving statutory grounds may also support best‑interest finding)
In re J.P.B., 180 S.W.3d 570 (Tex. 2005) (standards for legal sufficiency review in parental‑termination cases)
In re H.R.M., 209 S.W.3d 105 (Tex. 2006) (standards for factual sufficiency review)
In re E.D., 419 S.W.3d 615 (Tex. App.—San Antonio 2013) (past parental conduct can be used to predict future ability to parent for best‑interest analysis)