in the Interest of Z.M.M., a Child
Cases that cite this one
69 later published cases cite this decision. The 25 that cite it most often are listed here.
- in the Interest of S.P. and J.P. (Tex. App. 2022)
- in the Interest of Z.J. and D.J., Children (Tex. App. 2019)
- in the Interest of F. L. B., A. C. B., J. G. B., E. B. M., Children (Tex. App. 2019)
- In the Interest of B.M.P.J., a Child v. the State of Texas (Tex. App. 2024)
- In the Interest of A.A. Jr. and K.A., Children v. the State of Texas (Tex. App. 2024)
- In the Interest of A.C.R., a Child v. the State of Texas (Tex. App. 2023)
- In the Interest of S.C.M., a Child v. Department of Family and Protective Services (Tex. App. 2023)
- In the Interest of M.G., a Child v. the State of Texas (Tex. App. 2023)
- in the Interest of B.A. (Tex. App. 2021)
- in the Interest of A.W., a Child (Tex. App. 2021)
- in the Interest of Z.M.M., a Child (Tex. App. 2019)
- in the Interest of E.J.C, Jr., S.R.C., E.D.C., Children (Tex. App. 2019)
- In the Interest of M.N.M., a Child v. the State of Texas (Tex. App. 2025)
- B. C. and J. G. F. v. Texas Department of Family and Protective Services (Texas Court of Appeals, 3rd District (Austin) 2025)
- In the Interest of Z. J. G., J. R. G. and N. L. G. v. Department of Family and Protective Services (Tex. App. 2025)
- In the Interest of A.B., a Child v. the State of Texas (Tex. App. 2025)
- In the Interest of C.C., a Child v. the State of Texas (Tex. App. 2025)
- In the Interest of G.P.-J.R. and C.S.-L.R., Children v. the State of Texas (Tex. App. 2025)
- In the Interest of D.M. and D.M v. the State of Texas (Tex. App. 2024)
- In the Interest of C.W., a Child v. the State of Texas (Tex. App. 2024)
- In the Interest of Z.R.E.B., a Child v. the State of Texas (Tex. App. 2024)
- In the Interest of C.C. AKA C.C., Child v. Department of Family and Protective Services (Tex. App. 2024)
- In the Interest of J.S.H., a Child v. the State of Texas (Tex. App. 2024)
- In the Interest of J.S.H., a Child v. the State of Texas (Tex. App. 2024)
- In the Interest of J.R and J.R., Children v. the State of Texas (Texas Court of Appeals, 11th District (Eastland) 2024)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion
In this parental termination case, the trial court terminated the father's parental rights under three grounds for termination specified in the Texas Family Code-section 161.001(b)(1)(D), (N), and (O).
See
TEX. FAM. CODE § 161.001(b)(1)(D), (N), (O). The father appealed, challenging the sufficiency of the evidence as to all three grounds, and the court of appeals affirmed the trial
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court's order for termination based only on section 161.001(b)(1)(O) because an appellate court need only uphold one ground for termination on appeal.
Parental rights may be terminated under section 161.001(b)(1)(D) if clear and convincing evidence supports a finding that the parent "knowingly placed or knowingly allowed the child to remain in conditions or surroundings which endanger the physical or emotional well-being of the child." TEX. FAM. CODE § 161.001(b)(1)(D). Parental rights may be terminated under section 161.001(b)(1)(O) if clear and convincing evidence supports that the parent "failed to comply with the provisions of a court order that specifically established the actions necessary for the parent to obtain the return of the child."
Further, under section 161.001(d),
A court may not order termination under Subsection (b)(1)(O) based on the failure by the parent to comply with a specific provision of a court order if a parent proves by a preponderance of evidence that:
(1) the parent was unable to comply with specific provisions of the court order; and
(2) the parent made a good faith effort to comply with the order and the failure to comply with the order is not attributable to any fault of the parent.
TEX. FAM. CODE § 161.001(d). In its order for termination, the trial court found that the father did not prove by a preponderance of evidence that he "was unable to comply with specific provisions of a court order" and that he did not prove he "made a good faith effort to comply with the order and the failure to comply with the order [was] not attributable to any fault of the parent."
The trial court's finding that section 161.001(d) did not preclude termination under section 161.001(b)(1)(O) and the father's arguments on appeal should have alerted the court of appeals to the father's arguments under section 161.001(d). Courts must broadly construe issues to reach all core and substantive questions such that the merits of an appeal are addressed when reasonably possible to
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provide the party with a meaningful appeal.
See
Ditta v. Conte
,
In light of our holding in
In re N.G.
,
Case-law data current through December 31, 2025. Source: CourtListener bulk data.