in the Interest of S.S., F.C.S. and A.C.S., Jr., Children, 04-17-00072-CV

DFPS removed three children after an infant (A.C.S.) was found with multiple bone fractures and filed to terminate parents’ rights and obtain conservatorship in Dec. 2015.
Children placed with foster-adopt family; trial court ordered parents to complete family service plans including counseling.
Trial evidence included testimony from the parents, DFPS caseworker, foster mother, and Adelina’s counselor; documents included prior termination order for Adelina, a 2015 court finding against Adam regarding another child, and Adelina’s affidavit seeking a protective order.
Allegations included that Adam had a history of violence toward Adelina, potential role in injuring infant A.C.S., criminal history/incarcerations, and failure by both parents to complete services consistently.
Foster family had cared for the children since removal, provided therapy, planned to adopt, and children (two younger) were strongly bonded to foster mother; visits with parents produced mixed bonding.
Trial court terminated both parents’ rights, finding statutory grounds (not contested on appeal) and that termination was in the children’s best interest; parents appealed only the best-interest findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was legally and factually sufficient evidence that terminating Adelina’s and Adam’s parental rights is in the children’s best interest	Adelina and Adam: the evidence was insufficient to show termination is in the children’s best interest	DFPS: evidence of injuries to infant, parents’ histories (prior termination, violence, criminality), lack of bond with some children, incomplete services, and stable foster placement support termination	Court: Affirmed — a reasonable factfinder could form a firm belief termination was in children’s best interest

Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (sets multifactor best-interest framework)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (standard for clear-and-convincing proof in parental termination and importance of some factors)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (legal and factual sufficiency review in parental-termination cases)
In re J.P.B., 180 S.W.3d 570 (Tex. 2005) (deference to factfinder on credibility in termination cases)
In re O.N.H., 401 S.W.3d 681 (Tex. App.—San Antonio 2013) (past endangering conduct probative of best interest; caution against assuming past conduct alone resolves best interest)
In re D.M., 452 S.W.3d 462 (Tex. App.—San Antonio 2014) (factfinder may infer dangerous conduct will recur; parental arrests relevant to best-interest analysis)
In re J.D., 436 S.W.3d 105 (Tex. App.—Houston [14th Dist.] 2014) (consider bond with current caregiver for very young children)
In re C.J.F., 134 S.W.3d 343 (Tex. App.—Amarillo 2003) (civil proceedings permit adverse inference from invocation of Fifth Amendment)