Termination under § 19b(3)(j); “Harm”; In re Hudson; Principle that only one statutory ground is required; In re Laster; Children’s best interests; In re Moss Minors

Holding that § (j) was established and that termination was in the children’s best interests, the court affirmed the order terminating respondent-mother’s parental rights. She had a CPS history dating back to 2011, and evidence showed that the DHHS provided her with many services but she “could only maintain adequate parenting skills while the services were in place. Whenever services were scaled back to give respondent the opportunity to demonstrate adequate parenting skills, she became overwhelmed and reverted back to an inability to adequately parent the children. At the time of the termination hearing, respondent still had not” shown that she could take care of all five of her children together. Clinicians testified that the youngest child had “severe sensory issues” and “moderate-to-severe behavior needs,” and that, based on time spent with respondent, she “lacked the insight required to adequately help” the child. Another child indicated to “her therapist that she did not feel like she was appropriately cared for in respondent’s home, and that there were a lot of times where she had to parent her siblings, including the necessity to supervise the other children when respondent was not ‘present mentally.’ Respondent’s therapist also testified that respondent had issues with depression, lack of motivation, and self-care, and that she had not met her goals or completed working on those issues in therapy.” Two of the children’s therapists “testified that the children would be negatively impacted if they had to remain in foster care for another year while respondent continued to work toward reunification.” The court concluded that the evidence showed her “inability or unwillingness to change her behavior had already deprived her five children of several years of having a normal home life.” Thus, the trial court did not err in in finding that a strong likelihood existed that they would be harmed if returned to her care. It also considered the appropriate factors in determining that termination was in their best interests.