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In the Interest of S.C., Jr., J.A v. and K.A v. Children v. the State of Texas

2026-08-20

Summary

Holding. The court affirmed the trial court's judgment terminating Father's parental rights based on sufficient evidence that Father's criminal conviction and resulting imprisonment rendered him unable to care for the children for at least two years, and that termination served the children's best interests.

The Texas Department of Family and Protective Services sought to terminate Father's parental rights to two young children based on his criminal conduct and resulting imprisonment. Father had been convicted of domestic violence offenses and evading arrest, receiving concurrent sentences of twelve and fifteen years. At the time the children were removed from Mother's care, Father was incarcerated and unable to participate in most court-ordered services. The children were placed with foster parents who provided stable care and were willing to adopt them. The trial court terminated Father's parental rights on two statutory grounds: abandonment and criminal conduct resulting in imprisonment for at least two years, and also found termination served the children's best interests.

On appeal, Father challenged the sufficiency of evidence supporting the termination and raised a constitutional due-process argument. The appellate court rejected the constitutional claim because Father had not raised it at trial and because existing legal protections adequately safeguard parental rights. Regarding the sufficiency of evidence, the court found that Father failed to produce evidence that he had arranged for anyone other than Mother to care for the children during his incarceration. Since Mother herself had relapsed into substance abuse and had her own parental rights terminated, leaving the children in her care did not satisfy Father's obligation to arrange appropriate care. The court affirmed the termination judgment.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether incarcerated parent satisfied duty to arrange child care by leaving children with other parent who subsequently relapsed into substance abuse
  • Whether evidence sufficiently established inability to provide care for at least two years due to criminal conviction and imprisonment
  • Whether constitutional strict-scrutiny review applies to parental termination under Texas Family Code subsections (N) and (P)

Procedural posture

Father appealed the trial court's judgment terminating his parental rights to two children in a Department of Family and Protective Services proceeding.

Authorities cited

Opinion

majority opinion

In The

Court of Appeals

Seventh District of Texas at Amarillo

No. 07-26-00158-CV

IN THE INTEREST OF S.C., JR., J.A.V., AND K.A.V., CHILDREN

On Appeal from the 251st District Court

Randall County, Texas

Trial Court No. 85097C, Honorable Jack M. Graham, Associate Judge Presiding

August 20, 2026

MEMORANDUM OPINION

Before PARKER, C.J., and DOSS and YARBROUGH, JJ.

In this accelerated appeal, appellant, Father, seeks reversal of the trial court’s

judgment terminating his parental rights to his children, J.A.V. and K.A.V., in a suit brought

by the Texas Department of Family and Protective Services. 1 By his appeal, Father

challenges the sufficiency of the evidence to support the statutory grounds for termination

and asserts a due process violation. We affirm the trial court’s judgment.

1 To protect the privacy of the parties involved, we will refer to the appellant as “Father,” to the

children’s mother as “Mother,” and to the children by their initials. See TEX. FAM. CODE § 109.002(d); TEX. R. APP. P. 9.8(b).

BACKGROUND

Mother and Father have two children, three-year-old J.A.V. and two-year-old

K.A.V. Mother has another child the subject of this suit, eight-year-old S.C. The father

of S.C. was alleged to be “T.T.” but was ultimately unknown. Neither Mother nor the

unknown father appeal.

The Department became involved with Mother and the children in May of 2024

after receiving allegations of Mother’s substance abuse. One month later, Mother left an

inpatient drug treatment program and relapsed. The Department filed its petition for

termination on July 9, 2024. At the time the children were removed from Mother’s care,

Father was in jail and unavailable to serve as a placement option. He provided his sister’s

phone number to the caseworker for possible placement of the children. The caseworker

left a voice mail and sent a text message to Father’s sister, but she did not return the

caseworker’s phone call or reply to the text message.

The Department presented evidence concerning Father’s criminal history. On

August 6, 2024, Father pleaded guilty to two offenses arising from acts of domestic

violence against a female victim. Those offenses included assault causing bodily injury

by applying pressure to the throat or neck and/or blocking the nose or mouth of the victim

and striking the pregnant victim with his hand. He also pleaded guilty to the offense of

evading arrest with a vehicle. These offenses were enhanced by a previous conviction

for unlawful possession of a firearm by a felon. He received concurrent sentences of

twelve years’ and fifteen years’ incarceration, respectively, in the Institutional Division of

the Texas Department of Criminal Justice (TDCJ).

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A Department caseworker prepared a service plan for Father. Because of his

incarceration, Father was unable to participate in most services. As of the time of trial,

he was on a waiting list to attend the batterer’s intervention and prevention program

classes. Father has not regularly visited or maintained significant contact with the

children during the pendency of this case. According to the caseworker, Father’s parole

was denied and he has had difficulty adjusting to the institutional environment in a

favorable way. Because of his lengthy sentences, it would be at least another two years

before Father would again be eligible for parole.

The children were placed with a foster family on July 8, 2024. They have thrived

in their placement, and the foster parents have a great relationship with them. The foster

mother testified that she and her husband could meet the children’s physical, emotional,

therapeutic, and medical needs and would continue to facilitate sibling visits. The foster

parents are willing to adopt the children if parental rights are terminated.

The trial court terminated Father’s parental rights to the children on the grounds of

abandonment and engaging in criminal conduct resulting in his conviction, imprisonment,

and inability to care for the children for at least two years from the original petition’s file

date. See TEX. FAM. CODE § 161.001(b)(1)(N), (P). 2 The trial court also found termination

was in the best interest of the children. See § 161.001(b)(2). The Department was

appointed permanent managing conservator of the children. Father timely filed this

appeal of the resulting judgment.

2 Further references to provisions of the Texas Family Code will be by reference to “section ___”

or “§ ___.”

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APPLICABLE LAW

A parent’s right to the “companionship, care, custody, and management” of his or

her child is a constitutional interest “far more precious than any property right.” Santosky

v. Kramer, 455 U.S. 745, 758–59, 102 S. Ct. 1388, 71 L. Ed. 2d 599 (1982); see In re

M.S., 115 S.W.3d 534, 547 (Tex. 2003). We strictly scrutinize termination proceedings

and strictly construe the involuntary termination statutes in favor of the parent. Holick v.

Smith, 685 S.W.2d 18, 20 (Tex. 1985). However, “the rights of natural parents are not

absolute” and “[t]he rights of parenthood are accorded only to those fit to accept the

accompanying responsibilities.” In re A.V., 113 S.W.3d 355, 361 (Tex. 2003) (citing In re

J.W.T., 872 S.W.2d 189, 195 (Tex. 1994)). Recognizing that a parent may forfeit his or

her parental rights by his or her acts or omissions, the primary focus of a termination suit

is protection of the child’s best interests. See id.

In a case to terminate parental rights under section 161.001 of the Family Code,

the petitioner must establish, by clear and convincing evidence, that (1) the parent

committed one or more of the enumerated acts or omissions justifying termination, and

(2) termination is in the best interest of the child. § 161.001(b). Clear and convincing

evidence is “the measure or degree of proof that will produce in the mind of the trier of

fact a firm belief or conviction as to the truth of the allegations sought to be established.”

§ 101.007; In re J.F.C., 96 S.W.3d 256, 264 (Tex. 2002). Both elements must be

established and termination may not be based solely on the best interest of the child as

determined by the trier of fact. Tex. Dep’t of Human Servs. v. Boyd, 727 S.W.2d 531, 533

(Tex. 1987); In re K.C.B., 280 S.W.3d 888, 894 (Tex. App.—Amarillo 2009, pet. denied).

“Only one predicate finding under section 161.001[(b)](1) is necessary to support a

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judgment of termination when there is also a finding that termination is in the child’s best

interest.” In re A.V., 113 S.W.3d at 362. We affirm a termination order if the evidence is

both legally and factually sufficient to support any alleged statutory ground the trial court

relied upon in terminating parental rights if the evidence also establishes that termination

is in the child’s best interest. In re K.C.B., 280 S.W.3d at 894–95.

STANDARD OF REVIEW

In reviewing for legal sufficiency, we look at all the evidence in the light most

favorable to the finding to determine whether a reasonable trier of fact could have formed

a firm belief or conviction that the finding was true. In re J.O.A., 283 S.W.3d 336, 344−45

(Tex. 2009). In reviewing for factual sufficiency, we give due consideration to evidence

that the factfinder could reasonably have found to be clear and convincing. In re C.H., 89

S.W.3d 17, 27 (Tex. 2002). If, considering the entire record, the disputed evidence that

a reasonable factfinder could not have credited in favor of the finding is so significant that

a factfinder could not reasonably have formed a firm belief or conviction, then the

evidence is factually insufficient. In re J.F.C., 96 S.W.3d at 266.

The clear and convincing evidence standard does not mean the evidence must

negate all reasonable doubt or that the evidence must be uncontroverted. In re R.D.S.,

902 S.W.2d 714, 716 (Tex. App.—Amarillo 1995, no writ). The reviewing court must recall

that the trier of fact has the authority to weigh the evidence, draw reasonable inferences

therefrom, and choose between conflicting inferences. Id. The factfinder also enjoys the

right to resolve credibility issues and conflicts within the evidence and may freely choose

to believe all, part, or none of the testimony espoused by any witness. Id. Where

conflicting evidence is present, the factfinder’s determination on such matters is generally

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regarded as conclusive. In re B.R., 950 S.W.2d 113, 121 (Tex. App.—El Paso 1997, no

writ).

The appellate court cannot weigh witness credibility issues that depend on

demeanor and appearance as the witnesses are not present. In re J.P.B., 180 S.W.3d

570, 573 (Tex. 2005) (per curiam). Even when credibility issues are reflected in the

written transcript, the appellate court must defer to the factfinder’s determinations, if those

determinations are not themselves unreasonable. Id.

ANALYSIS

CONSTITUTIONAL CHALLENGE

We address Father’s third issue first because if it is sustained, it would give him

the greatest relief. Valk v. Copper Creek Distribs., Inc., 733 S.W.3d 9, 13 (Tex. 2026).

Relying on a recent amendment to the Texas Constitution, see TEX. CONST. art. I, § 37,

Father contends that termination of his parent-child relationship under the predicate

grounds (N) and (P) must satisfy strict scrutiny, that is, the parent-child relationship cannot

be terminated unless termination is the least restrictive means to satisfy a compelling

governmental interest.

To preserve a complaint for appellate review, the record must show, among other

things, that the party timely complained to the trial court and “stated the grounds for the

ruling that the complaining party sought from the trial court with sufficient specificity to

make the trial court aware of the complaint, unless the specific grounds were apparent

from the context.” TEX. R. APP. P. 33.1(a). Nothing in the record demonstrates that Father

raised his constitutional complaint in the trial court. Consequently, this issue is not

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preserved for our review. In re L.M.I., 119 S.W. 3d 707, 710–11 (Tex. 2003)

(constitutional claim relating to termination of parental rights was waived when not raised

in trial court); In re T.R., No. 01-25-00924-CV, 2026 Tex. App. LEXIS 3275, at *71–72

(Tex. App.—Houston [1st Dist.] Apr. 9, 2026, no pet. h.) (parent must complain to trial

court to preserve argument that termination must satisfy strict scrutiny); In re Z.D., Nos.

05-25-00138-CV, 05-25-00139-CV, 2025 Tex. App. LEXIS 5731, at *24 (Tex. App.—

Dallas Aug. 4, 2025, pet. denied) (mem. op.) (same). Further, even if the issue had been

preserved, we would decline to apply strict-scrutiny review to the trial court’s termination

order because existing protections sufficiently safeguard Father’s constitutional rights. In

re R.G., No. 02-25-00703-CV, 2026 Tex. App. LEXIS 4799, at *16 (Tex. App.—Fort Worth

May 21, 2026, pet. denied) (mem. op.).

After acknowledging his failure to preserve this complaint, Father asserts that the

doctrine of fundamental error allows review of his constitutional challenge. We construe

Father’s argument to contend that he need not object or complain to preserve this issue

on appeal because the doctrine of fundamental error applies. 3 However, the Texas

Supreme Court has specifically declined to extend the criminal fundamental error doctrine

to parental rights termination cases. In re B.L.D., 113 S.W.3d 340, 350–51 (Tex. 2003).

The court reasoned that “because termination cases do not apply criminal procedural or

evidentiary rules (that are only applicable to criminal cases), they do not necessarily

incorporate the concomitant criminal fundamental-error doctrine.” Id. at 351.

Fundamental errors may only be raised on appeal when not first raised in the trial court

3 In his brief, Father states that he “recognizes that the above due process argument is not the law

of the land” but he presents it in case the Texas Supreme Court were to alter that fact while this case is pending. The Texas Supreme Court has not done so.

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“in those rare instances in which the record shows the court lacked jurisdiction or that the

public interest is directly and adversely affected as that interest is declared in the statutes

or the Constitution of Texas.” Wal-Mart Stores, Inc. v. Alexander, 868 S.W.2d 322, 328

(Tex. 1993). “The simple fact that a constitutional right is involved is not sufficient to

render an issue one of fundamental error.” In re M.T., 290 S.W.3d 908, 910 (Tex. App.—

Tyler 2009, no pet.) (op. on reh’g). We overrule Father’s third issue.

CONVICTION AND IMPRISONMENT AND INABILITY TO CARE FOR CHILDREN

Father’s second issue challenges the sufficiency of the evidence to support the

trial court's finding under subsection (P), which permits termination if the court finds, by

clear and convincing evidence, that the parent has been convicted of an offense and

imprisoned and unable to care for his child for not less than two years. § 161.001(b)(1)(P);

In re A.V., 113 S.W.3d at 360. The Department must prove both that the parent will be

incarcerated or confined and unable to care for the child for at least two years. In re

H.R.M., 209 S.W.3d 105, 110 (Tex. 2006) (per curiam); see In re E.S.S., 131 S.W.3d 632,

639 (Tex. App.—Fort Worth 2004, no pet.) (“Proof that [the incarcerated parent] is unable

to care for [the child] is an additional requirement not met by showing incarceration

alone.”).

In In re Caballero, we held that a three-step process is employed to assess a

parent’s ability to care for a child while the parent is incarcerated. In re Caballero, 53

S.W.3d 391, 396 (Tex. App.—Amarillo 2001, pet. denied). First, the party seeking

termination must establish that the parent’s knowing criminal conduct resulted in

incarceration for more than two years. Id. Second, the parent must produce some

evidence as to how he would provide or arrange to provide care for the child during that

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period. Id. Finally, the party seeking termination would then have the burden of

persuasion that the arrangement would not satisfy the parent’s duty to the child. Id.

Here, Father does not dispute that he engaged in criminal conduct resulting in his

incarceration for at least two years from the date of the filing of the petition. He contends,

however, that at the time of his incarceration, he satisfied his duty of arranging care by

leaving the children with Mother, who already had physical possession of them and was

working family-based safety services with the Department. Because the Department had

allowed the children to remain with Mother while she addressed her substance abuse

issues, Father argues leaving the children in her care was an appropriate arrangement.

We disagree.

The record shows that at the time the Department filed its termination suit, Father

was incarcerated, and Mother had relapsed after leaving a drug rehabilitation facility.

Mother’s rights were terminated in this proceeding after the trial court concluded that she

endangered and abandoned the children. See § 161.001(b)(1)(D), (E), (N). “Absent

evidence that the non-incarcerated parent agreed to care for the child on behalf of the

incarcerated parent, merely leaving a child with a non-incarcerated parent does not

constitute the ability to provide care.” In re H.R.M., 209 S.W.3d at 110. “Cases discussing

the incarcerated parent’s provision of support through other people contemplate that the

support will come from the incarcerated parent’s family or someone who has agreed to

assume the incarcerated parent’s obligation to care for the child.” Id.; see, e.g., In re

E.S.S., 131 S.W.3d at 640. Father needed to produce some evidence of his ability to

arrange for care for the children other than Mother’s care. Such evidence appears

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nowhere in this record. No one testified that they were willing to care for the children on

Father’s behalf during his incarceration. See In re Caballero, 53 S.W.3d at 396. 4

Under the applicable legal and factual sufficiency standards, we conclude that the

evidence is sufficient to support the trial court’s finding under subsection (P) and overrule

Father’s second issue. Only one predicate ground is required to support termination

when there is also a finding that termination is in the child’s best interest. In re A.V., 113

S.W.3d at 362. Consequently, we need not address Father’s challenge in his second

issue regarding subsection (N). See TEX. R. APP. P. 47.1. As Father does not challenge

the sufficiency of the evidence supporting the best-interest finding, we affirm the trial

court’s order terminating Father’s parental rights to the children.

CONCLUSION

Having overruled Father’s appellate issues, we affirm the judgment of the trial court

terminating Father’s rights.

Judy C. Parker

Chief Justice

4 A Department caseworker testified that, at the time the children were removed, she contacted

Father at the county jail for placement options. Father provided his sister’s name and phone number for possible placement of the children. The caseworker testified that the Department attempted more than once to contact the aunt and she never returned any phone call or text message.

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