In the Interest of A.c., J.y., J.y. Jr., L.b., and E.b., Children

Summary

The Texas Supreme Court affirmed a termination decree supported by a mother's stipulations in a mediated settlement agreement (MSA), holding that her voluntary, unrecanted, and uncontroverted admission that termination was in her children's best interests—together with stipulations to statutory grounds and agreed permanency plans—is evidence sufficient under the clear-and-convincing-evidence standard. Extending its recent In re K.S.L. decision, which treated comparable affirmations in a sworn affidavit of voluntary relinquishment as ordinarily ample best-interest evidence, the Court perceived no legally cognizable difference in evidentiary value between the sworn affidavit and the unsworn but counsel-signed, judicially noticed MSA admitted without objection. The Court confined its holding to evidentiary sufficiency, expressly reserving questions about defenses to MSA enforcement and the effect of recanted admissions.