This question has been addressed in 1 Texas court opinion:
COA14 — January 29, 2026
The Fourteenth Court of Appeals affirmed a trial court’s order terminating a mother's parental rights based on a history of physical abuse and unresolved substance dependency. Although the mother maintained a documented bond with her children and partially completed her court-ordered service plan, the court applied the Holley factors to determine that the children's needs for safety and stability outweighed the parental relationship. The court held that evidence of the mother’s prior criminal history involving injury to a child and her failure to remain sober during the proceedings was legally and factually sufficient to support the best-interest finding for termination.
Litigation Takeaway
“A parent-child bond does not act as a "veto" against the termination of parental rights; courts prioritize a child's need for a safe, drug-free environment over emotional ties when a parent has a history of endangerment or ongoing substance abuse.”