Factual sufficiency

Like a submarine occasionally surfacing from the deep, the concept of factual suffiency review (as distinct from legal sufficiency) occasionally emerges in family-law cases about parental termination. While In re M.T. unanimously affirms a termination judgment, a concurrence argued that the evidence on one of the statutory grounds was factually insufficient. No. 05-20-00450-CV (Oct. 5, 2020) (mem. op.).