Texas Department of Human Services v. E.B

In Texas Department of Human Services v. E.B., 802 S.W.2d 647, 34 Tex. Sup. Ct. J. 31 (Tex. 1990), the Court approved submission of a single broad-form question incorporating two statutory grounds for termination of parental rights submitted disjunctively. 802 S.W.2d at 649. The Court rejected the court of appeals' conclusion that the form of the verdict deprived the parent of the necessary jury agreement on the specific grounds supporting termination, holding that the "controlling question in this case was whether the parent-child relationship between the mother and each of her two children should be terminated, not what specific ground or grounds under the statute the jury relied on to answer affirmatively the questions posed." Id.