that must be based on clear and convincing evidence cannot be viewed on appeal the same as one that may be sustained on a mere preponderance. See In re W.C., 56 S.W.3d 863, 868 (Tex.Civ.App.-Houston [14th Dist.] 2001, no pet.); In re K.R., 22 S.W.3d at 96-97 (Wittig, J., concurring). We hold that the appellate standard for reviewing termination findings is whether the evidence is such that a fact-finder could reasonably form a firm belief or conviction about the truth of the State’s allegations. That standard best comports with the Supreme Court’s holding in Santosky, with the definition of clear and convincing evidence we first adopted in Addington, and with the Legislature’s definition in the Family Code. See Santosky v. Kramer, 455 U.S. 745, 769, 102 S.Ct. 1388, 71 L.Ed.2d 599 (<HOLDING>); Addington, 588 S.W.2d at 570 (holding that
holding that in order to satisfy due process findings made at sentencing need only be based upon a preponderance of the evidence holding that a court is not required to accept legal conclusions cast in the form of factual allegations if those conclusions cannot reasonably be drawn from the facts alleged holding that the clearandconvincing standard adequately conveys to the factfinder the level of subjective certainty about his factual conclusions necessary to satisfy due process recognizing the circuit split and applying the subjective standard as more stringent without deciding which standard applies holding that in a proceeding to terminate parental rights the preponderance of the evidence standard of proof violates the due process clause and that due process requires at least a clear and convincing evidence standard