Samantha Soleil Aguilar v. Carrington Edvin Solis, 03-20-00121-CV

Mother (Aguilar) and father (Soliz) had a child, C.A., born 2007; parents separated after child’s birth and father had sporadic contact after 2016.
Aguilar sought to terminate Soliz’s parental rights; trial court denied termination but appointed Aguilar sole managing conservator.
Evidence at trial included allegations of poor conditions and CPS history in the paternal family, Soliz’s intermittent child support and limited involvement, and family trauma (grandfather’s murder conviction).
Court-appointed guardian ad litem recommended termination based on concerns about Soliz’s parenting, lack of involvement, and potential emotional harm to C.A.; guardian described C.A. as resistant/angry about reestablishing a relationship.
Trial court instead ordered supervised, therapeutic family-reunification visitation and drug testing for Soliz with a one-year supervised program before unsupervised possession could begin.
Aguilar appealed the denial of termination; the appellate court reviewed whether the trial court’s refusal to terminate was contrary to the overwhelming weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence was factually sufficient to overturn the trial court’s denial of Aguilar’s petition to terminate Soliz’s parental rights	Aguilar: she proved statutory grounds and that termination was in C.A.’s best interest by clear and convincing evidence	Soliz: trial court reasonably concluded best interest not proven; visitation plan and supervised reunification address risks; appellate court must defer to trial-court credibility findings	Affirmed: appellate court held the trial court’s failure to form a firm conviction that termination was required was not contrary to the overwhelming weight of the evidence

In re S.J.R.-Z., 537 S.W.3d 677 (Tex. App.—San Antonio 2017) (termination implicates fundamental constitutional rights; requires strict scrutiny)
Holick v. Smith, 685 S.W.2d 18 (Tex. 1985) (termination divests parent and child of legal rights; due-process concerns)
In re A.C., 560 S.W.3d 624 (Tex. 2018) (explains and applies the clear-and-convincing standard in parental-rights cases)
Dow Chem. Co. v. Francis, 46 S.W.3d 237 (Tex. 2001) (factual-sufficiency standard principles; contrasted with heightened standard in termination appeals)
Burns v. Burns, 434 S.W.3d 223 (Tex. App.—Houston [1st Dist.] 2014) (articulates heightened appellate review for denial of termination)
In re A.L.D.H., 373 S.W.3d 187 (Tex. App.—Amarillo 2012) (discusses appellate burden in termination appeals)
In re M.I.A., 594 S.W.3d 595 (Tex. App.—San Antonio 2019) (party seeking termination must show both statutory grounds and best interest contrary to overwhelming evidence)
In re J.P.B., 180 S.W.3d 570 (Tex. 2005) (appellate courts must defer to trial-court credibility determinations)
In re E.J.R., 503 S.W.3d 536 (Tex. App.—Corpus Christi-Edinburg 2016) (framework for reviewing termination appeals)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (sets out Holley best-interest factors)
J.G. v. Texas Dep’t of Fam. & Protective Servs., 592 S.W.3d 515 (Tex. App.—Austin 2019) (presumption that maintaining biological parent-child relationship serves child’s best interest)