in the Interest of R.R., Jr. E.R.R. E.B.R. And J.S.R., Children, 11-15-00041-CV

Four children (ages ~3–10) were removed after findings of neglect/unsafe home conditions; Department placed them with paternal aunt and uncle who were willing to adopt.
Mother had prior involvement with DFPS (2005, 2010); in 2010 child tested positive for cocaine during a drug raid; mother received deferred adjudication for abandonment/endangerment.
In the 2013–2014 case investigators found the maternal grandmother’s home unfit (poor sleeping arrangements, insufficient food, disrepair) and learned mother admitted recent methamphetamine and marijuana use, including use in the home with children present.
Mother failed to complete most court-ordered services (parenting classes, psychological evaluation, counseling, MHMR evaluation, and most drug screens); she submitted one negative drug screen and completed only a drug/alcohol assessment.
Mother had limited contact with children (no face-to-face visits ~14 months, few phone calls), lacked stable housing/transportation/phone, and acknowledged children should not wait for her to get into rehab.
Trial court terminated parental rights of both parents under multiple statutory grounds (mother did not contest those statutory findings) and found termination was in the children’s best interest; mother appealed.

Issue	Mother's Argument	Department/Father's Argument	Held
Whether evidence was legally and factually sufficient to show termination of mother’s parental rights was in children’s best interest	Mother argued relative placement with mother as possessory conservator would be better; termination not required	Department argued Holley factors and statutory grounds support termination and adoption by relatives	Court held evidence was clear and convincing and legally and factually sufficient to find termination in children’s best interest; mother’s issues 1–2 overruled
Whether mother may challenge sufficiency of evidence supporting termination of father’s parental rights	Mother challenged termination of father’s rights on sufficiency grounds	Department argued mother lacked standing to complain about errors affecting only father’s rights because she was not harmed	Court held mother lacked standing to raise issues about father’s rights (no justiciable interest); issues 3–4 overruled

In re J.P.B., 180 S.W.3d 570 (Tex. 2005) (standard for legal sufficiency review in termination cases)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (standard for factual sufficiency review in termination cases)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (factors for determining best interest of the child)
Torrington Co. v. Stutzman, 46 S.W.3d 829 (Tex. 2000) (appellate standing; cannot complain about errors that do not injuriously affect appellant)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (discussing interplay of evidence and best-interest findings)
In re C.J.O., 325 S.W.3d 261 (Tex. App.—Eastland 2010) (statutory grounds may also support best-interest conclusion)