context: Section 161.001(1)(E) of the Family Code provides that parental rights may be terminated if the parent has "engaged in conduct or knowingly placed the child with persons who engaged in conduct which endangers the physical or emotional well-being of the child."
citation_a.signal: see
citation_a.identifier: 727 S.W.2d 531, 533
citation_a.parenthetical: stating that although endangerment requires more than threat of metaphysical injury or possible ill effects of less-than-ideal family environment, it is not necessary that parent's conduct be directed at child or that child actually suffers injury
citation_a.sentence: J.O.A., 283 S.W.3d at 345 (holding that father’s history of domestic violence toward mother, admitted marijuana use, and previous incarceration on criminal charges that were later dismissed constituted legally sufficient evidence of endangerment); see Tex. Dep’t of Human Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex.1987) (stating that although endangerment requires more than threat of metaphysical injury or possible ill effects of less-than-ideal family environment, it is not necessary that parent’s conduct be directed at child or that child actually suffers injury); Robinson v. Tex. Dep’t of Protective & Regulatory Servs., 89 S.W.3d 679, 686 (Tex.App.-Houston [1st Dist.] 2002, no pet.) (stating that “to endanger” means to expose child to loss or injury or to jeopardize child’s emotional or physical health); In re M.N.G., 147 S.W.3d 521, 536 (Tex.App.-Fort Worth 2004, pet. denied) (holding that courts may look to parental conduct both before and after child’s birth to determine whether termination is appropriate, that parent’s conduct need not be directed at child, and that danger to child’s well-being may be inferred from parental misconduct standing alone).
citation_b.signal: no signal
citation_b.identifier: 283 S.W.3d 345, 345
citation_b.parenthetical: holding that father's history of domestic violence toward mother, admitted marijuana use, and previous incarceration on criminal charges that were later dismissed constituted legally sufficient evidence of endangerment
citation_b.sentence: J.O.A., 283 S.W.3d at 345 (holding that father’s history of domestic violence toward mother, admitted marijuana use, and previous incarceration on criminal charges that were later dismissed constituted legally sufficient evidence of endangerment); see Tex. Dep’t of Human Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex.1987) (stating that although endangerment requires more than threat of metaphysical injury or possible ill effects of less-than-ideal family environment, it is not necessary that parent’s conduct be directed at child or that child actually suffers injury); Robinson v. Tex. Dep’t of Protective & Regulatory Servs., 89 S.W.3d 679, 686 (Tex.App.-Houston [1st Dist.] 2002, no pet.) (stating that “to endanger” means to expose child to loss or injury or to jeopardize child’s emotional or physical health); In re M.N.G., 147 S.W.3d 521, 536 (Tex.App.-Fort Worth 2004, pet. denied) (holding that courts may look to parental conduct both before and after child’s birth to determine whether termination is appropriate, that parent’s conduct need not be directed at child, and that danger to child’s well-being may be inferred from parental misconduct standing alone).