Rather, a court looks for a parent's failure to comply. See In re J.S., 291 S.W.3d 60, 67 (Tex. App.—Eastland 2009, no pet.) (holding subsection (O) does not intend evaluation of parent's partial achievement of plan requirements); see also In re A.W., No. 01-15-01030-CV, 2016 WL 3022824, at *7 (Tex. App.—Houston [1st Dist.] May 26, 2016, no. pet.) (mem. op.) (holding substantial compliance with court-ordered FSP may be insufficient to avoid termination).

See, e.g., In re J.S., 291 S.W.3d 60, 66–67 (Tex.App.-Eastland 2009, no pet.) (affirming termination where mother complied with parts of service plan but did not obtain stable housing, employment, or basic necessities for children); In re C.M.C., 273 S.W.3d 862, 874–876 (Tex.App.-Houston [14th Dist.] 2008, no pet.) (declining to reverse termination on mother's argument of substantial compliance with service plan); Liu v. Dep't of Family and Protective Servs., 273 S.W.3d 785, 801–802 (Tex.App.-Houston [1st Dist.] 2008, no pet.) (affirming termination of schizophrenic mother's parental rights despite partial compliance with service plan because she failed to take prescribed medications as required by plan, resulting in hallucinations and violent behavior); In re T.T., 228 S.W.3d 312, 317–321 (Tex.App.-Houston [14th Dist.] 2007, no pet.) (affirming termination where mother failed to comply with four of seven requirements and father failed to comply with three of seven requirements); In re C.D.B., 218 S.W.3d 308, 311–312 (Tex.App.-Dallas 2007, no pet.) (affirming t

Subsection (O) does not quantify any particular number of provisions of the family service plan that a parent must fail to achieve for parental rights to be terminated or the degree of a parent's conduct that will be deemed to be a failure to achieve a particular requirement of the service plan. See id.; In re B.H.R., 535 S.W.3d 114, 122 (Tex. App.-Texarkana 2017, no pet.). Neither the statute nor the order that the trial court entered prescribes the degree to which the parent must comply with the court order, and neither the order nor the statute "make[s] provision for excuses" for a parent's failure to comply with such an order. See Tex. Fam. Code Ann. § 161.001(b)(1)(O); In re J.S., 291 S.W.3d 60, 67 (Tex. App.- Eastland 2009, no pet.) (quoting In re T.N.F., 205 S.W.3d 625, 631 (Tex. App.-Waco 2006, pet. denied), overruled on other grounds by In re A.M., 385 S.W.3d 74, 79 (Tex. App.-Waco 2012, no pet.)).

Although Mother disputed much of the evidence offered under ground (O) and completed some of the Plan's requirements, this ground "does not quantify any particular number of provisions of the family service plan that a parent must not achieve in order for the parental rights to be terminated" and "does not encompass an evaluation of a parent's partial achievement of plan requirements to determine whether or not the parent failed to comply." In re J.S. , 291 S.W.3d 60, 67 (Tex. App.—Eastland 2009, no pet.) ; seeIn re B.H.R. , 535 S.W.3d 114, 122 (Tex. App.—Texarkana 2017, no pet.) (declining to reverse termination where mother achieved some of the plan's goals); In re C.M.C. , 273 S.W.3d 862, 874–76 (Tex. App.—Houston [14th Dist.] 2008, no pet.) (declining to reverse termination on mother's argument of substantial compliance with service plan); In re T.T. , 228 S.W.3d 312, 317–21 (Tex. App.—Houston [14th Dist.] 2007, pet. denied) (affirming termination where mother failed to comply with four of seven requirements and father failed to comply with three of seven requirements); In re C.D.B. , 218 S.W.3d 308, 311–12 (Tex. App.—Dallas 2007, no pet.) (affirming termination based on mother's partial compliance with service plan); In re A.D. , 203 S.W.3d 407, 411–12 (Tex. App.—El Paso 2006, no pet.) (affirming termination because mother failed to meet family service plan's material requirements including drug assessment, finding a job, and providing a safe home). Despite the fact that Mother c

"Subsection O [also] does not provide a means to evaluate 'excuses' or 'partial compliance.'" In re S.J.R.-Z., 2017 WL 6502563, at *9; see also In re J.S., 291 S.W.3d 60, 67 (Tex. App.—Eastland 2009, no pet.) (holding subsection (O) "does not encompass an evaluation of a parent's partial achievement of plan requirements"). "In other words, 'substantial compliance is not the same as complete compliance.'"

Subsection O does not provide a means to evaluate "excuses" or "partial compliance." Id. ; see alsoIn re J.S. , 291 S.W.3d 60, 67 (Tex. App.—Eastland 2009, no pet.) (holding subsection (O) does not intend evaluation of parent's partial achievement of plan requirements); In re T.N.F. , 205 S.W.3d 625, 631 (Tex. App.—Waco 2006, pet. denied) (holding any excuse for failure to complete family service plan is only relevant to best interest determination). In other words, "substantial compliance is not the same as complete compliance."

Subsection O does not provide a means to evaluate "excuses" or "partial compliance." Id.; see also In re J.S., 291 S.W.3d 60, 67 (Tex. App.—Eastland 2009, no pet.) (holding subsection (O) does not intend evaluation of parent's partial achievement of plan requirements); In re T.N.F., 205 S.W.3d 625, 631 (Tex. App.—Waco 2006, pet. denied) (holding any excuse for failure to complete family service plan is only relevant to best interest determination). In other words, "substantial compliance is not the same as complete compliance."

See In re J.F.C., 96 S.W.3d at 278 ("[S]poradic incidents of partial compliance do not alter the undisputed fact that the parents violated many material provisions of the trial court's orders."); cf. In re J.S., 291 S.W.3d 60, 66-67 (Tex. App.—Eastland 2009, no pet.) (affirming termination under subsection (O) where trial court noted parent had made progress in last few months). And the record also indicates that S.O. did not provide her school grades to her caseworker and did not complete her individual and group therapy requirements.

While addressing whether "imperfect compliance" with a family service plan should result in termination, the Texas Supreme Court has stated that "whether a parent has done enough under the family-service plan to defeat termination under subpart (O) is ordinarily a fact question." Id.; see In re J.S., 291 S.W.3d 60, 67 (Tex. App.—Eastland 2009, no pet.) (noting that Family Code has no provisions regarding partial compliance or excuses for noncompliance and applying factual sufficiency standard to parent's challenge to termination of her parental rights following partial compliance). Mother testified that she began the required outpatient therapy in November 2013.

However, subsection (O) looks only for a parent's failure to comply with a court order, without reference to quantity of failure or degree of compliance. See In re J.S., 291 S.W.3d 60, 67 (Tex. App.—Eastland 2009, no pet.). It does not provide a means of evaluating partial or substantial compliance with a plan.