Holley v. Adams

In Holley v. Adams, 544 S.W.2d 367 (Tex. 1976), the Court developed a list of non-exhaustive factors for determining a minor's best interests. Four of these factors are relevant when adapted to the parental notification context, and a trial court should consider them in determining best interests: (1) the minor's emotional or physical needs; (2) the possibility of emotional or physical danger to the minor; (3) the stability of the minor's home and whether notification would cause serious and lasting harm to the family structure; (4) the relationship between the parent and the minor and the effect of notification on that relationship. See Holley, 544 S.W.2d at 371-72.