Under subsection (E), "endangerment" has the same definition as in subsection (D), "but the grounds of subsections (D) and (E) are otherwise different." See In re J.K.N.G., No. 04-21-00310-CV, 2022 WL 689095, at *5 (Tex. App.-San Antonio Mar. 9, 2022, pet. denied) (mem. op.). To terminate parental rights pursuant to subsection (E), the Department must prove by clear and convincing evidence the parent "engaged in conduct or knowingly placed the child with persons who engaged in conduct" that endangered the child's "physical or emotional well-being."

Jenna's decision to remain in this environment until October 2020-a year after the children were removed-was a voluntary, deliberate, and conscious course of conduct[,] and we may infer danger to the children from it. In re J.K.N.G., No. 04-21-00310-CV, 2022 WL 689095, at *6 (Tex. App.-San Antonio Mar. 9, 2022, pet. denied) (mem. op.).

Although both grounds require proof of endangerment, they are otherwise separate and distinct grounds. See A.S. v. Tex. Dep't of Fam. & Protective Servs., 394 S.W.3d 703, 713 (Tex. App.-El Paso 2012, no pet.); In re S.H.A., 728 S.W.2d 73, 85 (Tex. App.-Dallas 1987, writ ref'd n.r.e.); see also In re J.K.N.G., No. 04-21-00310-CV, 2022 WL 689095, at *5 (Tex. App.-San Antonio Mar. 9, 2022, pet. denied) (mem. op.).

Although both grounds require proof of endangerment, they are otherwise separate and distinct grounds. See A.S. v. Tex. Dep't of Fam. & Protective Servs., 394 S.W.3d 703, 713 (Tex. App.-El Paso 2012, no pet.); In re S.H.A., 728 S.W.2d 73, 85 (Tex. App.-Dallas 1987, writ ref'd n.r.e.); see also In re J.K.N.G., No. 04-21-00310-CV, 2022 WL 689095, at *5 (Tex. App.-San Antonio Mar. 9, 2022, pet. denied) (mem. op.). The primary distinction between subsections (D) and (E)