We therefore conclude that the trial court had jurisdiction to proceed with the trial in July 2024 and to order termination of Mother's parental rights to Iris and appoint the Department as Iris's permanent managing conservator. See id. at *5-6; J.W.W., 2024 WL 630869, at *11; L.D.R., 2021 WL 5104376, at *3; see also In re. Z.E., No. 05-22-01337-CV, 2023 WL 3595627, at *3 (Tex. App.-Dallas May 23, 2023, pet. denied)
, the trial court's judgment implies all findings of fact necessary to support it." In re Z.E., No. 05-22-01337-CV, 2023 WL 3595627, at *5 (Tex. App.-Dallas May 23, 2023, pet. denied) (mem. op.) (citing Shields Ltd. P'ship v. Bradberry, 526 S.W.3d 471, 480 (Tex. 2017)). "Despite the profound constitutional interests at stake in a proceeding to terminate parental rights, '"the rights of natural parents are not absolute; protection of the child[ren] is paramount."'
When, as in this case, "findings of fact and conclusions of law are not properly requested and none are filed, the trial court's judgment implies all findings of fact necessary to support it." In re Z.E., No. 05-22-01337-CV, 2023 WL 3595627, at *5 (Tex. App.-Dallas May 23, 2023, pet. denied) (mem. op.)
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).
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)
(quoting Phillips, stating, "an alleged father who admits paternity can 'stave off summary termination of his rights [under [S]ection 161.002(b)(1)] and require[] the Department to meet the high burden of proof found in [S]ection 161.001.'"). In re Z.E., No. 05-22-01337-CV, 2023 WL 3595627, at *4 (Tex. App.-Dallas May 23, 2023, pet. denied) (mem. op.). Moreover, the manner and means of admitting paternity is not restricted to the filing of an Acknowledgment of Paternity or a pleading claiming paternity but may be established in various ways. In re E.G.P., No. 09-22-00330-CV, 2023 WL 4013306, at *9 (Tex. App.-Beaumont June 15, 2023, no pet.) (mem. op. on reh'g).
We recently noted that it is unclear how the rules announced in In re N.G., 577 S.W.3d 230, 237 (Tex. 2019) (per curiam), apply in Anders cases. See 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.). Out of an abundance of caution, we will detail the evidence supporting our conclusion that legally and factually sufficient evidence supports the jury's finding that Mother engaged in conduct that endangered G.G.-H.'s physical or emotional well-being.
Because this is a case involving termination of parental rights, appointed counsel's duties continue through the filing of a petition for review in the supreme court. See in re Z.E., No. 05-22-01337-CV, 2023 WL 3595627, at *7 (Tex. App.-Dallas May 23, 2023, no pet. h.) (mem. op.)