M. C. v. Texas Department of Family and Protective Services, 03-17-00104-CV

CPS removed one-year-old J.C. after M.C. and J.C.’s father were arrested at a residence where the child was present; M.C. later was arrested in a hotel where drugs were found with an infant present.
The Department sought termination; an associate judge recommended termination and M.C. elected a de novo district-court hearing where the associate-judge transcript plus additional testimony were admitted.
Evidence showed M.C. had prior CPS involvement and had voluntarily relinquished rights to three older children; she pleaded no contest to hindering apprehension and public lewdness and received deferred adjudication.
Testimony and records indicated M.C. had untreated or partially treated mental-health diagnoses, unstable housing, positive drug tests during the case (which she contested), and ongoing associations with persons who used drugs and had criminal histories.
J.C. was placed with his great-grandmother (B.V.), where he was bonded, healthy, and thriving; B.V. wished to keep the children together and sought to adopt J.C.
The district court found statutory grounds for termination and that termination was in J.C.’s best interest by clear-and-convincing evidence; this appeal challenges only the best-interest finding.

Issue	Plaintiff's Argument (M.C.)	Defendant's Argument (Department)	Held
Whether evidence is legally and factually sufficient to support that termination is in child’s best interest	Termination is not in J.C.’s best interest; M.C. argues she is a good mother when treated, denies ongoing drug use, and has a prepared home and support network	M.C.’s criminal history, positive drug tests, untreated mental illness, unstable housing, and risky associates endanger the child; J.C. is thriving in a stable, bonded placement	Affirmed: evidence both legally and factually sufficient to find termination in child’s best interest

In re K.M.L., 443 S.W.3d 101 (Tex. 2014) (parental rights termination requires heightened scrutiny)
Santosky v. Kramer, 455 U.S. 745 (U.S. 1982) (clear-and-convincing standard in parental termination cases)
In re J.F.C., 96 S.W.3d 256 (Tex. 2002) (standards for legal sufficiency review in termination proceedings)
In re C.H., 89 S.W.3d 17 (Tex. 2002) (standards for factual sufficiency review and Holley factors)
In re A.B., 437 S.W.3d 498 (Tex. 2014) (review standards and constitutional considerations in termination appeals)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (factors to determine best interest of the child)
Holick v. Smith, 685 S.W.2d 18 (Tex. 1985) (parental rights are constitutional in nature)
In re J.L., 163 S.W.3d 79 (Tex. 2005) (deference to factfinder on credibility in termination cases)