Texas Court of Appeals, Fifth District · 1987
In the Interest of S.H.A., 728 S.W.2d 73 (Tex. App. 1987)
The court treated parental acts and omissions causing severe malnutrition and failure to obtain medical care as endangering conduct and held that lack of education, training, or misfortune is a best-interest factor rather than an automatic defense. This older authority has cautionary treatment and should not be read to make poverty itself a termination ground.
Some later courts have distinguished or questioned it — read before relying.
Treatment last confirmed August 19, 2026. Case-wide subsequent treatment; human-set. Not specific to any one passage.