Termination under §§ 19b(3)(c)(i) & (g); Best interests of the children; In re Moss Minors; In re Olive/Metts Minors

Holding that termination was in the children’s (MP and LG) best interests, the court affirmed termination of respondent-mother’s parental rights. Her parental rights were terminated based on physical abuse. On appeal, the court rejected her argument that termination was not in the children’s best interests as the trial court failed to adequately consider “the principle that ‘a child’s placement with relatives weighs against termination.’” It noted that the record showed the trial court “expressly took this factor into consideration, but nonetheless determined that termination of respondent’s parental rights was in each child’s best interests.” As to each child, the trial court “recognized that relative placement weighed against termination but identified adequate reasons why termination was nonetheless warranted. Given the children’s need for stability and the lack of any indication that respondent would be able to provide stability,” the trial court did not err in its best-interests determinations. The court also rejected respondent’s claim that the trial court should have considered custody orders instead of termination, noting it “repeatedly encouraged the parties to pursue this avenue throughout the case. Ultimately, however, MP’s father did not want respondent in MP’s life, and LG’s grandparents were not ready to enter into a guardianship over LG.”