8.Because B.L.D. holds that the broad-form jury charge violates due process rights of parents through the creation of a conflict
between Rules 277 and 292, the court's holding is in conflict with E.B. Compare E.B., 802 S.W.2d at 649 (holding broad-form
submission does not violate due process), with B.L.D., 56 S.W.Sd at 219 (concluding broad-form submission did not allow appellate
review; thereby violating due process). While B.L.D. distinguishes E.B., because that case did not analyze Rule 292, it is
important to note that the E.B. court did acknowledge ten jurors agreed appellant endangered her children. B.L.D., 56 S.W.3d
at 215-16; see E.B., 802 S.W.2d at 649 (noting ten jurors agreed on termination); see also In re M.C.M., 57 S.W.3d 27, 31
n. 2 (Tex.App--Houston [1st Dist.] 2001, no pet.) (following E.B. and holding trial court properly submitted the controlling
issue in that case through its broad-form submission).
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