In the Interest of A.B. and H.B., Children

Summary

The Texas Supreme Court affirmed the en banc court of appeals' termination of Father's parental rights, holding that courts of appeals performing factual sufficiency reviews in termination cases must consider the entire record but are not required to detail the relevant evidence in their opinions when they affirm the factfinder's decision — the detailing requirement attaches only to reversals, where it guards against the reviewer usurping the jury's role. The Court declined to import the exemplary-damages practice from Moriel, reasoning that termination aims to protect the child rather than punish the parent, that the Family Code's enumerated grounds and mandatory best-interest finding constrain jury discretion, and that the State's competing fundamental interest together with statutory and appellate safeguards amply protects the parent's constitutional rights. Because the en banc court had cited the correct standard and considered the record in its entirety, its affirmance stood.