Her inability to complete services due to her confinement was not an extraordinary circumstance but was instead the consequence of poor choices. See In re M.S., 602 S.W.3d at 680 (citing In re C.J.B., No. 05-19-00165-CV, 2019 Tex.App. LEXIS 7470, at *32 (Tex. App.-Dallas Aug. 21, 2019, no pet.) (mem. op.))

(mem. op.); see also In re C.J.B., No. 05-19-00165-CV, 2019 Tex.App. LEXIS 7470, at *29 (Tex. App.- Dallas Aug. 21, 2019, no pet.) (mem. op.).

Because the evidence concerning the (D) and (E) termination grounds is interrelated, courts may consolidate examination of the record. In re C.J.B., No. 05-19-00165-CV, 2019 WL 3940987, at *6 (Tex. App.-Dallas Aug. 21, 2019, no pet. h.) (mem. op.). At trial in the present case, documentary evidence and witness testimony established, among other things, that:

Because the evidence concerning the (D) and (E) termination grounds is interrelated, courts may consolidate examination of the record. In re C.J.B., No. 05-19-00165-CV, 2019 WL 3940987, at *6 (Tex. App.-Dallas Aug. 21, 2019, no pet. h.) (mem. op.). At trial in the present case, documentary evidence and witness testimony established, among other things, that:

The relevant inquiry under subsection (E) is whether evidence shows that the endangerment of the child's well-being was the direct result of the parent's conduct, including acts, omissions, or failures to act. In re C.J.B., No. 05-19-00165-CV, 2019 WL 3940987, at *6 (Tex. App.-Dallas Aug. 21, 2019, no pet.) (mem. op.).

See In re J.W., 645 S.W.3d at 741. Based on the record in this case, a reasonable factfinder could have resolved the disputed facts related to Mother's drug use by finding that the evidence showed that she used drugs while pregnant and that this use endangered her children under subsections (D) and (E). See id. at 749 (stating that "[c]ertainly, Mother's use of controlled substances while pregnant created a dangerous environment for [her baby]…."); see also In re C.J.B., No. 05-19-00165, 2019 WL 3940987 (Tex. App.-Dallas Aug. 21, 2019, no pet.) (mem. op.) (stating that a mother's use of drugs during pregnancy may amount to conduct that endangers the physical or emotional well-being of the child).

Drug use during pregnancy, which Mother engaged in, may amount to conduct that endangers the physical and emotional well-being of the child. In re C.J.B. , No. 05-19-00165-CV, 2019 WL 3940987, at *7 (Tex. App.—Dallas Aug. 21, 2019, no pet.) (mem. op.). And continued illegal drug use after a child's removal is conduct that jeopardizes parental rights and may be considered as establishing an endangering course of conduct.

Because the evidence concerning these two statutory grounds for termination is interrelated, we will analyze subsections (D) and (E) together. In re C.J.B., No. 05-19-00165-CV, 2019 WL 3940987, at *6 (Tex. App.-Dallas Aug. 21, 2019, no pet.) (mem. op.)

In re C.J.B., No. 05-19-00165-CV, 2019 WL 3940987, at *6 (Tex. App.-Dallas Aug. 21, 2019, no pet.) (mem. op.)

"[U]nlawful conduct by a parent . . . can create an environment that endangers the physical and emotional well-being of a child as required for termination under [Ground] (D)." In re C.J.B., No. 05-19-00165-CV, 2019 WL 3940987, at *6 (Tex. App.-Dallas Aug. 21, 2019, no pet.) (mem. op.). "Endanger," as used in the definition of Ground D, "means to expose to loss or injury; to jeopardize." Tex. Dep't of Human Servs. v. Boyd, 727 S.W.2d 531, 533 (Tex. 1987); see In re L.E.S., 471 S.W.3d at 923.