Termination under § 19b(3)(c)(i); In re White; In re Ellis; Best interests of the children; In re Trejo Minors; In re HRC; In re Ferranti; In re Gonzales/Martinez; In re Olive/Metts Minors

Holding that termination of respondent-mother’s parental rights was appropriate under § (c)(i), and it was in the children’s (JK and J) best interests, the court affirmed. The trial court terminated respondent’s parental rights under § (c)(i) because more than 182 days had elapsed since the initial dispositional order was issued and she “failed to rectify the conditions—namely respondent’s housing and ability to provide proper care and custody—that led to the adjudication.” The trial court further determined that there was no reasonable likelihood she would rectify these issues within a reasonable time. The court found no clear error in either determination. This case was initiated in 2018. “After numerous referrals and pressure from respondent’s foster-care specialist and the trial court, respondent finally obtained housing in July or August 2019.” To obtain this housing, she sought funds from donations. After obtaining housing, she failed to show “that she would be able to maintain it by providing receipts of rent or utility payments, or by verifying her employment.” Similarly, although she “initially benefited from parenting-education classes and earned unsupervised parenting time with the minor children, that parenting time was revoked after respondent began to regress. Respondent could not consistently pass drug screens, could not maintain healthy boundaries with the minor children, and could not provide the children with structure or redirection whatsoever. As respondent relapsed, she failed to consistently participate in the services offered to her.” The court noted that at the time of termination, JK was six years old and J was three years old. “These proceedings spanned more than 17 months and, besides obtaining housing, respondent made little to no progress over that period of time.” With all of that in mind, the court could not find error in the trial court’s determination “that respondent failed to rectify the conditions that led to adjudication, and that there was no reasonable likelihood that" she would be able to do so in a reasonable time.