
The house feels different when your child isn’t there. The toys are still on the floor. The nightlight still glows in the hallway. But the laughter, the questions, the ordinary chaos of family life—it’s suddenly quiet. And in that silence, one question keeps rising to the surface: How Does a Texas CPS Removal Involve Conservatorship and what does that mean for my rights as a parent?
If Child Protective Services has removed your child, it can feel like everything ended in a single moment. But legally, that moment is the beginning of a process—not the end of your parent-child relationship. Under Texas Family Code Chapter 262, CPS may seek emergency removal when it believes a child faces immediate danger. After removal, the agency typically asks the court to appoint it as Temporary Managing Conservator. That term—conservatorship—is critical. It refers to decision-making authority, not automatic termination of parental rights.
Here is the immediate insight many parents don’t hear clearly enough: conservatorship determines who makes major decisions for your child during the case, but it does not erase you as a parent. Termination of parental rights is a separate and much higher legal hurdle under Texas Family Code Chapter 161, requiring clear and convincing evidence. The law builds in hearings, review periods, and opportunities for reunification.
At The Law Office of Bryan Fagan, PLLC, we understand how overwhelming those first days can be. Bryan Joseph Fagan, a South Texas College of Law graduate and recognized authority on Texas divorce and custody law, has spent years guiding families through CPS and conservatorship cases across Houston and throughout Texas. Our mission is rooted in something simple but powerful: empowering people to reclaim freedom and peace of mind during life’s hardest transitions. We believe that when parents understand the law, fear loses some of its grip.
Texas courts make conservatorship decisions using the “best interest of the child” standard found in §153.002 of the Texas Family Code. Judges examine safety, stability, parental progress, and long-term welfare. They evaluate whether concerns can be addressed through services, whether relatives are appropriate placements, and whether reunification is realistic. Conservatorship is not punishment; it is a legal structure designed to protect children while the court determines what arrangement serves them best.
Families often come to us believing CPS “took custody forever.” In reality, most cases involve temporary managing conservatorship while parents work service plans, attend hearings, and demonstrate stability. There are status hearings, permanency hearings, and statutory timelines—including the one-year dismissal deadline under §263.401—that create accountability for both parents and the agency.
What you’ll learn in the sections ahead is how conservatorship actually works in Texas CPS cases, what rights parents retain, how timelines affect your case, and how experienced legal advocacy can influence outcomes. More importantly, you’ll see that even in the middle of uncertainty, there is structure, process, and opportunity within the law.
When the house feels quiet and the future feels unclear, knowledge becomes power. Let’s walk step by step through what conservatorship means, how Texas courts approach these cases, and how you can begin moving forward with clarity and confidence.
Key Takeaways
- When CPS removes a child in Texas, the agency typically seeks Temporary Managing Conservatorship, which grants legal decision-making authority but does not automatically terminate parental rights
- Parents retain certain rights during CPS conservatorship and can pursue family reunification through court-ordered service plans and demonstrated compliance
- Conservatorship can be temporary or permanent—removal alone does not guarantee permanent loss of child custody
- Understanding the legal process and timeline helps parents protect their rights and navigate court hearings effectively
- Legal representation from a court appointed attorney or private attorney is crucial during child protective services cases to safeguard parental rights
How Does a Texas CPS Removal Involve Conservatorship? The Short Answer
When families ask, How Does a Texas CPS Removal Involve Conservatorship, the answer begins with understanding what actually happens in court. When the Texas Department of Family and Protective Services (DFPS) removes a child, it files a petition under Texas Family Code Chapter 262 asking the court to appoint the agency as Temporary Managing Conservator. This legal status gives DFPS authority over key decisions such as placement, medical care, and educational matters. However, temporary managing conservatorship is not the same as termination of parental rights. Termination requires a separate proceeding under Texas Family Code §161.001 and must be proven by clear and convincing evidence along with a best-interest finding under §153.002.
Under Texas law, conservatorship defines who holds decision-making authority—not who loves the child more or who “wins” custody. Chapter 153 of the Texas Family Code governs conservatorship generally, while Chapters 262 and 263 outline the procedures and timelines in CPS cases. When DFPS is appointed Temporary Managing Conservator, parents may temporarily lose certain rights to direct the child’s daily life, but they remain the child’s legal parents unless and until the court orders otherwise. The appointment is designed to be temporary while the court evaluates safety, permanency planning, and whether reunification is possible within statutory deadlines, including the one-year dismissal rule found in §263.401.
For parents navigating CPS involvement alongside divorce or custody litigation, careful coordination matters. Actions taken during a CPS investigation can affect parallel family court proceedings. Families are encouraged to review How to Cooperate with DFPS Without Compromising Your Divorce Proceedings to understand how to protect both their parental rights and their broader legal strategy. Cooperation with DFPS is often necessary, but it must be informed and measured.
The Houston family law team at The Law Office of Bryan Fagan, PLLC has guided Texas parents through the conservatorship process across multiple counties, helping them understand service plans, adversary hearings, and permanency reviews under Chapter 263. As part of our commitment to educating families and protecting futures, we emphasize that CPS removal marks the beginning of a structured legal process—not the end of your rights. With accurate knowledge of the Texas Family Code and strategic legal guidance, parents can move forward with clarity, compliance, and a plan aimed at reunification whenever possible.
If you want to better understand your rights in a CPS case, you may also find our resource on Texas Child Custody and Conservatorship helpful. Knowledge reduces uncertainty, and informed action protects what matters most.

What Is Conservatorship Under Texas Law?
Conservatorship is the legal framework Texas uses for what many parents informally call custody. Under Texas Family Code Chapter 153, conservatorship determines who has the authority to make major decisions affecting a child’s life, including residence, medical care, education, and other matters tied to the child’s welfare. When families ask, How Does a Texas CPS Removal Involve Conservatorship, the answer begins with understanding this distinction. Conservatorship defines legal authority—not simply where the child sleeps at night—and that distinction becomes critically important in cases involving the Texas Department of Family and Protective Services (DFPS).
Texas law recognizes two primary types of conservatorship under §153.005 and related provisions. A Managing Conservator holds primary decision-making authority, including the right to determine the child’s primary residence and consent to medical and educational decisions. A Possessory Conservator has court-ordered possession and access rights but more limited decision-making authority. In standard divorce cases, parents are often appointed Joint Managing Conservators under §153.131 unless evidence rebuts that presumption. However, CPS cases operate under additional provisions in Chapters 262 and 263 of the Texas Family Code, which address emergency removals and court oversight following DFPS intervention.
When DFPS is appointed Temporary Managing Conservator under Chapter 262, the agency—not the parent—holds the authority to determine placement, approve medical treatment, and control educational decisions while the court evaluates safety and permanency. Parents are often designated as possessory conservators with specific rights outlined in the temporary order. That means parents retain defined rights such as notice of hearings, participation in service plans, and the opportunity to pursue reunification. They do not “disappear” from the legal picture. Instead, the law provides a structured process, including status hearings and permanency reviews under Chapter 263, to determine whether conservatorship should be returned, modified, or made permanent.
It is also important to distinguish conservatorship from physical possession. A relative—such as a grandparent—may provide daily care, but if DFPS holds Temporary Managing Conservatorship, DFPS maintains ultimate legal decision-making authority. This legal separation between possession and conservatorship is central to understanding CPS cases. For a deeper look at how courts analyze custody and DFPS involvement, families can review Understanding Custody in the Context of DFPS Valuations, which explains how judges weigh safety factors and parental rights under the Texas Family Code.
The Houston family law team at The Law Office of Bryan Fagan, PLLC emphasizes that conservatorship in CPS matters is governed by statute and subject to strict timelines, including the dismissal deadline in §263.401. As part of our mission to educate families and protect futures, we encourage parents to understand not just the terminology, but the procedural safeguards built into the law. For additional guidance on parental rights and custody matters in Texas, you may also explore our Texas Child Custody Resource. Knowledge of the statutory framework transforms confusion into clarity—and clarity empowers parents to move forward strategically and confidently.
What Happens Immediately After a CPS Removal?
The moments and days following an emergency removal are legally critical. Understanding the timeline helps parents know what to expect and when to act.
Emergency Court Orders and Legal Filings
Under Texas Family Code Chapter 262, CPS may remove a child based on immediate danger to the child’s physical health or safety. Emergency removal can occur without prior court approval when circumstances indicate the child faces immediate risk. However, DFPS must take legal action quickly.
Within one business day of removal, DFPS must file a suit affecting the parent child relationship (often called a SAPCR) and request a court order authorizing continued possession of the child. The court reviews this emergency filing and determines whether DFPS should receive DFPS temporary custody pending further hearings.
At the initial hearing, which typically occurs within 14 days, the court examines whether DFPS should be named Temporary Managing Conservator. This hearing—sometimes called an adversary hearing—is the first opportunity for parents to contest removal and present evidence that their children should come home.
During emergency proceedings, parents retain fundamental rights, including the right to legal representation. A parent’s attorney or court appointed attorney plays a critical role in challenging removal and protecting the parent’s rights from the earliest stages.
Temporary Managing Conservatorship in CPS Cases
When the court names DFPS as Temporary Managing Conservator following an initial hearing, the agency gains specific legal authority over the child—but this authority is temporary and subject to ongoing court oversight.
DFPS Authority as Temporary Managing Conservator
As Temporary Managing Conservator, DFPS has the right to:
- Determine where the child lives (whether in foster care, with foster parents, or with relatives)
- Make decisions about the child’s medical records and medical treatment
- Control educational decisions and school enrollment
- Determine visitation schedules for parents and family members
Even when a child is placed with a family member or family friend, DFPS retains decision-making authority as managing conservator. The relative may handle day-to-day care, but DFPS makes final calls on major decisions affecting the child’s placement.
However, temporary managing conservatorship doesn’t mean parents have no rights. Parents typically retain:
- The right to be notified of court hearings
- The right to legal representation
- The right to visitation (usually supervised, as ordered by the court)
- The right to participate in permanency planning meetings
- The right to work toward reunification through a service plan
Courts often name parents as Temporary Possessory Conservators during CPS cases, which preserves certain parental rights while DFPS manages the child’s placement and major decisions.
The path toward family reunification runs through compliance with court ordered services. At the initial hearing or status hearing, courts approve a service plan outlining what parents must do to demonstrate they can safely care for their children. This plan typically addresses the safety concerns that led to removal and may include parenting classes, counseling, substance abuse treatment, housing stability requirements, and other services.
How Conservatorship Is Determined at the Adversary Hearing
When families ask, How Does a Texas CPS Removal Involve Conservatorship, the adversary hearing is one of the most important stages in the answer. Under Texas Family Code §262.201, the court must hold an adversary hearing within approximately 14 days after an emergency removal. This hearing determines whether the Texas Department of Family and Protective Services (DFPS) will continue as Temporary Managing Conservator or whether the child can safely return home. It is not a formality. It is a legally mandated safeguard designed to prevent unnecessary separation while protecting children from genuine danger.
At the adversary hearing, DFPS carries the burden of proof. The agency must demonstrate that continued possession of the child is necessary to protect the child’s physical health or safety and that there are no reasonable alternatives to removal. The CPS caseworker and the attorney representing DFPS present testimony and documentary evidence describing the alleged circumstances that led to removal. The court evaluates whether emergency action was justified and whether ongoing separation remains necessary under the statutory framework.
Parents are not passive participants in this process. Through counsel, they have the right to challenge DFPS’s evidence, cross-examine witnesses, present testimony, and propose alternative safety arrangements. Texas courts also consider whether Family-Based Safety Services under Chapter 262 could adequately protect the child without continued removal. Judges review factors such as the specific safety risks identified, the alleged perpetrator’s relationship to the child, whether a responsible relative is available for placement, and the child’s immediate medical or emotional needs. The child’s attorney ad litem, appointed under Texas Family Code Chapter 107, participates independently and may provide the court with the child’s perspective.
The Houston family law team at The Law Office of Bryan Fagan, PLLC regularly advises parents that preparation for the adversary hearing can significantly influence the direction of the case. Possible outcomes include the return of the child with court-ordered protective services in place, continued temporary managing conservatorship with DFPS, placement of the child with a qualified relative while DFPS retains legal authority, or dismissal of the case if DFPS fails to meet its burden. Each outcome carries long-term implications for conservatorship under Chapters 153 and 263 of the Texas Family Code.
For parents navigating the early stages of a CPS matter, it is critical to understand both your rights and your responsibilities. Our firm has created guidance on Navigating DFPS Investigations in Houston to help families prepare strategically without escalating tensions unnecessarily. You may also find it helpful to review our overview of Texas Child Protective Services cases to better understand timelines and court expectations.
The adversary hearing is not the end of your rights; it is the first structured review in a process governed by statutory safeguards and judicial oversight. With accurate knowledge of Texas Family Code provisions and thoughtful legal advocacy, parents can approach this pivotal hearing with clarity rather than fear.

What Happens to Parental Rights During CPS Conservatorship
One of the most important points for parents to understand is that CPS conservatorship does not mean immediate termination of parental rights. Under Texas law, terminating parental rights is a separate legal process requiring clear and convincing evidence—a much higher standard than what’s required for temporary removal.
During temporary managing conservatorship, parents retain their fundamental legal status as parents. They have the right to attend all court hearings, the right to visitation (typically supervised), the right to participate in developing and reviewing service plans, and the right to work toward reunification.
Courts expect parents to actively participate in their service plan. The service plan becomes the roadmap for reunification, and courts evaluate parental progress at every permanency hearing and status hearing. Completing parenting classes, maintaining stable housing, passing drug tests (if applicable), attending counseling, and demonstrating consistent engagement with court ordered services all factor into whether children return home.
Supervised visitation during CPS conservatorship serves multiple purposes: it maintains the bond between parent and child while protecting the child’s welfare. Parents should treat every visit as an opportunity to demonstrate appropriate parenting and emotional connection with their children.
Can Conservatorship Become Permanent After CPS Removal?
When parents ask, How Does a Texas CPS Removal Involve Conservatorship, one of the most important stages to understand is the permanency phase. Temporary Managing Conservatorship granted under Texas Family Code Chapter 262 does not automatically become permanent. Instead, Chapter 263 establishes a structured review process to determine whether the child can safely return home or whether another long-term arrangement is required. The law requires judicial oversight at regular intervals, ensuring that permanency decisions are guided by statutory standards—not assumptions.
Under Texas Family Code §263.302, the initial permanency hearing must occur no later than 180 days after DFPS is appointed Temporary Managing Conservator. At that hearing, the court reviews the permanency plan, which must include both a primary goal and a concurrent goal. The primary goal is often reunification, while the concurrent goal may involve placement with relatives or adoption if reunification efforts fail. The court evaluates parental progress on the service plan, the child’s safety, placement stability, and whether the statutory dismissal deadline under §263.401 is approaching.
Several permanency outcomes are legally possible. If parents have substantially complied with their court-ordered service plan and resolved the safety concerns that led to removal, the court may modify conservatorship and return the child home. Placement with relatives remains a preferred option under Texas law when appropriate, and a qualified family member may be appointed Permanent Managing Conservator if that arrangement serves the child’s best interest under §153.002. In some cases, DFPS or another qualified party may receive Permanent Managing Conservatorship without terminating parental rights, allowing parents to retain limited visitation and modification rights under Chapter 156. Termination of parental rights and adoption are considered only when statutory grounds under Texas Family Code §161.001 are proven by clear and convincing evidence and when termination is also found to be in the child’s best interest.
For parents balancing a CPS matter with ongoing divorce or custody proceedings, coordination is critical. Actions taken during permanency reviews can affect conservatorship determinations in parallel family court cases. Families navigating this overlap may benefit from reviewing What to Do If DFPS Contacts You During a Divorce to understand how to protect both parental rights and broader litigation strategy. Additional guidance on conservatorship and custody issues can be found in our Texas Child Custody Resource, which outlines how courts analyze best-interest factors across different types of cases.
The Houston family law team at The Law Office of Bryan Fagan, PLLC emphasizes that permanency hearings are not simply procedural checkpoints; they are decision-making milestones governed by statute and evidence. Judges focus on measurable progress, compliance with service plans, housing and employment stability, and demonstrated protective capacity. While the process can feel overwhelming, it is designed to move cases toward a safe and legally sound resolution. With informed preparation and strategic advocacy, parents place themselves in the strongest position to pursue reunification and protect their family’s future.
How the Best Interest of the Child Standard Applies in CPS Conservatorship Cases
Every conservatorship decision in Texas CPS cases is governed by the best interest of the child standard established in Texas Family Code §153.002. This standard requires courts to consider what arrangement best serves the child’s safety, emotional needs, physical health, and overall wellbeing.
When evaluating conservatorship in CPS cases, courts consider:
- The child’s current safety and stability
- The child’s emotional and physical needs
- Parental progress on service plans
- The ability of parents to provide appropriate care going forward
- The child’s own wishes (depending on age and maturity)
- Available family placements
- The child’s attachment to current caregivers
The best interest standard means that courts balance family preservation against child protection. Texas law and policy favor keeping families together when safe, but courts won’t return children to environments where safety concerns remain unresolved.
Common Myths About CPS Removal and Conservatorship
When families begin asking, How Does a Texas CPS Removal Involve Conservatorship, they are often operating under fear-based assumptions. One of the most common misconceptions is that removal automatically means permanent loss of a child. Texas law does not support that belief. Under Texas Family Code Chapter 262, removal initiates a court-supervised process, not a final termination of parental rights. Parents retain fundamental legal protections, including the right to notice, representation, and the opportunity to complete a service plan under Chapter 263. Termination requires a separate proceeding under Texas Family Code §161.001 and must be proven by clear and convincing evidence along with a best-interest finding under §153.002.
Another persistent myth is that CPS becomes the child’s “parent forever.” In reality, Temporary Managing Conservatorship is exactly what the statute says—temporary. Texas Family Code §263.401 requires dismissal of the case within one year from the date DFPS is appointed Temporary Managing Conservator, unless the court grants a single extension of up to 180 days for extraordinary circumstances. The law builds in status hearings, permanency hearings, and judicial review to move the case toward reunification or another permanent solution. The statutory framework exists to prevent indefinite state control.
Some parents also believe they immediately lose every decision-making right. While DFPS may receive Temporary Managing Conservatorship, parents are often designated Temporary Possessory Conservators and retain defined rights outlined in the court’s order. Even when certain rights are suspended for safety reasons, parents continue to participate in service planning, visitation, and court hearings. Texas Family Code Chapter 107 ensures children are represented by an attorney ad litem, and parents have the right to counsel to protect their interests throughout the process.
A final misconception is that once DFPS is appointed conservator, nothing can change. That is simply not accurate under Texas law. Conservatorship is reviewed repeatedly at adversary, status, and permanency hearings. Courts examine measurable progress, compliance with service plans, housing stability, and protective capacity. Parents who demonstrate safety and consistency can and do regain conservatorship when statutory requirements are met. For those who disagree with agency recommendations or court findings, resources such as What to Do If You Disagree with a DFPS Decision provide practical guidance on preserving rights and responding strategically.
The Houston family law team at The Law Office of Bryan Fagan, PLLC consistently emphasizes education as empowerment. Understanding the statutory process transforms uncertainty into clarity. Parents seeking additional insight into how conservatorship works in broader family law matters can explore our Texas Child Custody Resource, which explains how courts evaluate best-interest factors under Chapter 153. The law is structured, not arbitrary, and informed parents are better positioned to protect their children and their

How Parents Can Work Toward Regaining Conservatorship
Parents facing CPS conservatorship have concrete steps they can take:
- Complete all court ordered services thoroughly and on time
- Attend every court hearing without exception
- Participate actively in visitation and permanency planning meetings
- Demonstrate housing, employment, and lifestyle stability
- Maintain appropriate communication with your CPS caseworker
- Document your progress and keep records of compliance
- Work closely with your attorney to prepare for each hearing
How a Texas CPS Attorney Helps With Conservatorship Cases
A skilled attorney makes a significant difference in CPS conservatorship cases. An experienced legal representation helps by challenging removal orders, protecting parental rights at every stage, advocating effectively at adversary and permanency hearings, monitoring DFPS compliance with legal requirements, and developing strategic approaches to reunification.
Understanding how does a Texas CPS removal involve conservatorship requires legal knowledge most parents don’t have. An attorney ensures you understand your rights, meet legal deadlines, and present your case effectively.
Why Choose The Law Office of Bryan Fagan, PLLC
The Law Office of Bryan Fagan, PLLC brings extensive experience to Texas CPS removal and conservatorship cases. Our attorneys understand Texas Family Code Chapters 262 and 263 inside and out. We provide child-focused, rights-protective legal strategies while offering clear communication and compassionate guidance throughout the process. We represent Texas families statewide.

Checklist: How Does a Texas CPS Removal Involve Conservatorship
- Understand whether DFPS has been granted Temporary Managing Conservatorship
- Review all court orders carefully and understand what they require
- Attend all scheduled hearings without exception
- Comply fully with your court-ordered service plan
- Consult with an experienced Texas CPS attorney immediately
- Document your progress and maintain records of compliance
- Communicate appropriately with caseworkers and your legal representatives
Conclusion
When you’re facing a CPS case, it can feel like your world has narrowed down to court dates, paperwork, and worst-case scenarios. But the bigger picture still matters. Conservatorship is not just a legal label—it’s a process with structure, safeguards, and opportunities built into it. Understanding how that process works gives you something incredibly important: direction. And direction brings hope.
The truth is, most parents don’t need more fear. They need clarity. They need to know what the law actually says, what judges are really looking for under the “best interest of the child” standard, and what practical steps can move them forward. When you understand how conservatorship functions in a Texas CPS case, you’re no longer reacting in panic—you’re responding with strategy. That shift can make all the difference.
At The Law Office of Bryan Fagan, PLLC, we believe families deserve steady guidance during unstable seasons. Our mission has always been to educate, protect, and empower Texas parents so they can reclaim peace of mind and build a stronger future. Whether your case involves temporary managing conservatorship, permanency hearings, or the risk of termination, working with an experienced Texas Family Law Attorney ensures your rights are protected and your voice is heard in court.
If you’re feeling uncertain about what comes next, that’s completely understandable. But you don’t have to navigate this alone. Schedule a consultation with our team and let’s talk about your specific situation. Ask your questions. Get real answers. Develop a plan.
Because even in the middle of legal uncertainty, one thing remains true: informed parents make stronger decisions. And sometimes the first step toward protecting your family’s future is simply reaching out for the right guidance.
Frequently Asked Questions
If Texas CPS has temporary managing conservatorship, it means a judge has granted the Department of Family and Protective Services (DFPS) the legal authority to make major decisions for your child during an ongoing case. This includes decisions about where the child lives, medical care, and education. Importantly, this does not automatically terminate your parental rights. Parents typically still have the right to attend hearings, receive visitation (often supervised), and work a court-ordered service plan aimed at reunification.
One of the biggest mistakes parents make in custody disputes is allowing emotion to drive decisions instead of focusing on the child’s best interest. Judges are looking for stability, cooperation, and maturity. Ignoring court orders, refusing to communicate respectfully, involving children in adult conflict, or using social media to vent frustrations can significantly damage your credibility in court.
CPS can remove a child when there is evidence that the child is in immediate danger or at serious risk of harm. Common grounds include neglectful supervision, physical abuse, sexual abuse, substance abuse affecting parental care, domestic violence creating unsafe conditions, or hazardous living environments. A judge must review the removal quickly, and CPS must prove that the removal was necessary for the child’s safety.
A conservatorship order can limit a parent’s decision-making authority and impose structured visitation schedules or specific restrictions. In CPS cases, temporary managing conservatorship means parents must comply with a service plan under strict deadlines. Failure to comply can impact long-term parental rights. While restrictive, conservatorship also creates clear expectations and a roadmap for reunification or stability.
Texas CPS laws are updated periodically through legislative sessions. Changes may affect court timelines, parental rights protections, placement preferences, or procedural requirements. Because laws evolve, it’s important to consult a knowledgeable Texas family law attorney who can explain the most current version of the Texas Family Code and how recent updates apply to your case.
Conservatorship is Texas’s legal term for custody. A managing conservator has primary decision-making authority over the child, while a possessory conservator typically has visitation rights and limited decision-making powers. In CPS cases, DFPS is often appointed temporary managing conservator. In divorce cases, parents may be named joint managing conservators, sharing rights and duties according to court orders.
Judges are often frustrated by parents who disregard court orders, arrive unprepared, show disrespect in the courtroom, or escalate conflict unnecessarily. Courts value parents who demonstrate reliability, honesty, and a child-focused mindset. Showing cooperation and emotional control—even in difficult circumstances—can positively influence a judge’s perception.
The “70/30 rule” is not an official Texas legal standard. It usually refers to a parenting time arrangement where one parent has the child approximately 70 percent of the time and the other has 30 percent. In Texas, many custody arrangements follow the Standard Possession Order unless modified by agreement or court decision based on the child’s best interest.
Behaviors that suggest instability or poor judgment can hurt a custody case. Examples include substance abuse, repeated missed visitations, exposing a child to unsafe individuals, violating temporary orders, or attempting to alienate the child from the other parent. Courts carefully evaluate whether a parent promotes a stable, supportive environment and encourages a healthy relationship with the other parent when safe to do so.

