, "due process and due course of law requirements mandate that an appellate court detail its analysis for an appeal of termination of parental rights under section 161001(b)(1)(D) or (E) of the Family Code" In re NG, 577 S.W.3d 230, 237 (Tex 2019) (per curiam) That Court has not definitively instructed, however, whether an appellate court must detail its analysis of the evidence supporting (D) and (E) grounds for termination in the Anders context See In re EK, 608 S.W.3d 815, 815 (Tex 2020) (Green, J, concurring in denial of petition for review). At least two

The extent to which appellate courts must address termination under family code subsections 161001(b)(1)(D) and (E) in the Anders context is unclear See In re NG, 577 S.W.3d 230, 233- 37 (Tex 2019) (holding that due process and due course of law require appellate analysis of terminations under family code subsections 161001(b)(1)(D) and (E)); see also In re EK, 608 S.W.3d 815, 815 (Tex 2020) (Green, J, concur ring in denial of petition for review) (stating that the issue of how In re N.G. applies in the Anders context is "an important question" the supreme court "should answer").

Our Court has noted that it is unclear whether we are required to detail our analysis of (D) and (E) termination grounds in Anders cases. In re Z.E., No 05-22-01337-CV, 2023 WL 3595627, at *3, *6 (Tex App-Dallas May 23, 2023, pet denied) (mem op); see In re E.K., 608 S.W.3d 815, 815 (Tex 2020) (Green, J, concurring in denial of petition for review) (highlighting that the supreme court has not yet addressed whether an Anders brief triggers the requirement to review (D) and (E) termination findings).

(mem op); see In re EK, 608 S.W.3d 815, 815 (Tex 2020) (Green, J, concurring in denial of petition for review) (highlighting that the supreme court has not yet addressed whether an Anders brief triggers the requirement to review (D) and (E) termination findings). Out of an abundance of caution, we will review the evidence supporting our conclusion that no plausible grounds for appeal exist regarding whether legally and factually sufficient evidence supports the trial court's findings that Mother placed the child in conditions which endangered the physical and emotional wellbeing of the child and that Mother engaged in conduct that endangered the child's physical and emotional well-being.

In an ordinary appeal, the Texas Supreme Court has held that "due process and due course of law requirements mandate that an appellate court detail its analysis for an appeal of termination of parental rights under Section 161.001(b)(1)(D) or (E)." In re N. G, 577 S.W.3d 230, 237 (Tex 2019) (per curiam) That court has not decided whether a court of appeals is required to address findings in an Anders disposition of a termination of parental rights on predicate grounds (D) or (E) See In re EK, 608 S.W.3d 815, 815-16 (Tex 2020) (Green, J, concurring in denial of petition for review) (citing N.G., 577 S.W.3d at 230 (Tex. 2019)

But see In re E.K., 594 S.W.3d 435, 438 n.4 (Tex. App.-Waco July 31, 2019, pet. denied) (mem. op.) (Gray, C.J. concurring) (declining to impose the holding in In re N.G. to an Anders termination appeal "until the Supreme Court of Texas makes it clear that N.G. applies to this type of appeal"). See also In re E.K., 608 S.W.3d 815, 815 (Tex. 2020) (Green, J. concurring in denial of petition for review). We have independently examined the entire record to determine whether there are any non-frivolous issues which might support the appeal.

The extent to which appellate courts must address termination under family code subsections 161001(b)(1)(D) and (E) in the Anders context is unclear See In re NG, 577 S.W.3d 230, 233-37 (Tex 2019) (holding that due process and due course of law require appellate analysis of terminations under family code subsections 161001(b)(1)(D) and (E)); see also In re EK, 608 S.W.3d 815, 815 (Tex 2020) (Green, J, concurring in denial of petition for review) (stating that the issue of how In re N.G. applies in the Anders context is "an important question" the supreme court "should answer").

See In re E.K., 608 S.W.3d 815, 815 (Tex. 2020) (Green, J., concurring in denial of petition for review). Analysis

However, due to the significant collateral consequences that may result from such findings, even when we affirm the termination of a parent's rights on another ground, we must consider the sufficiency of the evidence regarding subsections (b)(1)(D) and (E) when raised on appeal, although the extent to which we must do so in an Anders context is unclear. See In re E.K., 608 S.W.3d 815, 815 (Tex. 2020) (Green, J., concurring in denial of petition for review) (stating the issue of how In re N.G. applies to parental termination appeals in which the appellant's counsel has filed an Anders brief is “an important question” [the Texas Supreme Court] should answer”).

n conditions or surroundings which endanger the physical or emotional well-being of the child, pursuant to § 161001(b)(1)(D), Texas Family Code"; (2) "engaged in conduct or knowingly placed the child with persons who engaged in conduct which endangers the physical or emotional well-being of the child, pursuant to § 161001(b)(1)(E), Texas Family Code"; (3) "constructively abandoned the children pursuant to § 161001(b)(1)(N), Texas Family Code"; (4) "failed to comply with the provisions of a court order that specifically established the actions necessary for the father to obtain the return of the child pursuant to § 161001(b)(1)(O), Texas Family Code"; and (5) "used a controlled substance in a manner that endangered the health or safety of the child pursuant to § 161001(b)(1)(P), Texas Family Code" The Texas Supreme Court has not decided whether a court of appeals is required to address findings in an Anders disposition of a termination of parental rights on predicate grounds D or E See In re EK, 608 S.W.3d 815, 815-16 (Tex 2020) (Green, J, concurring in denial of petition for review) (citing In re N.G., 577 S.W.3d 230 (Tex. 2019)).