In the Interest of N.g., a Child

Summary

The Texas Supreme Court, per curiam, held that due process and due course of law entitle a parent to appellate review of Family Code section 161.001(b)(1)(D) and (E) findings whenever the parent presents the issue on appeal, even if another ground alone would sustain termination, because unreviewed D/E findings become an independent basis (through section 161.001(b)(1)(M)) to terminate parental rights to other children. It further held that a court of appeals errs by affirming termination under section 161.001(b)(1)(O) without addressing whether the trial court's order—including the incorporated service plan—was sufficiently specific to apprise the parent of the actions required to regain custody. Applying these rulings, the Court reversed the Dallas court of appeals' judgment affirming termination of the mother's parental rights and remanded for further proceedings.