What is the summary of In the Interest of N.L.S. and E.J.C., Children?

The Texas Supreme Court reversed the court of appeals and held that legally sufficient evidence supported the trial court’s finding that Father engaged in conduct that endangered his child’s physical or emotional well‑being under Tex. Fam. Code § 161.001(b)(1)(E). The case is remanded to the court of appeals to address unresolved factual‑sufficiency and best‑interest issues.

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In the Interest of N.L.S. and E.J.C., Children

Supreme Court of Texas — June 13, 2025

Litigation Takeaway

"This opinion reinforces that a coherent, cumulative narrative of risk — including criminal convictions that indicate violence or substance abuse, evidence of recurrent incarceration, and limited or inconsistent parental involvement — can satisfy legal sufficiency under § 161.001(b)(1)(E)."

Analysis by Thomas J. Daley

Lead Litigation Attorney

Thomas J. Daley is a board-certified family law attorney. He has guided more than 225 clients to successful resolution of their cases over his 18 years of experience.

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