Weekly Digest
June 7 – June 13, 2025
2 opinions this week
In the Interest of N.L.S. and E.J.C., Children
Supreme Court of Texas
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.
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).”
City of Houston v. Jessica Zuniga
Supreme Court of Texas
The Supreme Court of Texas denied the City of Houston’s petition for review, leaving in place the court of appeals’ conclusion that the City had actual notice under Tex. Civ. Prac. & Rem. Code § 101.101(c), allowing the negligence claim to proceed to the merits. Justice Young emphasized the need for doctrinal clarity regarding actual notice requirements.
Litigation Takeaway
“For family-law practitioners, ensure jurisdictional footing when dealing with governmental entities by serving formal notice within deadlines or proving actual notice through documented evidence. Anticipate jurisdictional pleas and rely on plain statutory language to argue actual notice.”