Termination under § 19b(3)(c)(i); Children’s best interests

Holding that § (c)(i) existed and termination of respondent-mother’s parental rights was in the children’s best interests, the court affirmed. Evidence presented at the termination hearing established that she showed a general lack of parenting skills throughout the case. Her inability to control them and her discipline style directly impacted their “behavior toward each other and contributed to their sometimes acting out following in person visits with respondent.” The court noted that this “proceeding spanned more than two years and multiple services, but yielded no demonstrable improvement in respondent’s parenting skills.” Respondent contended that termination was premature because she had obtained housing, a vehicle, was employed, and had taken classes at a shelter for women, but she had been unable to show “what she had learned due to COVID-19 restrictions on in-person parenting. In light of the services respondent had received over the course of the previous two years, not to mention the services she received in 2017, during CPS’s prior involvement, and the absence of appreciable benefit from those services,” the court found unpersuasive the suggestion that she “would have been able to internalize and apply lessons learned during two additional months of services in any significant way.” The court concluded that the trial court did not clearly err in holding that there was no reasonable likelihood that she would be able to rectify her parenting skills within a reasonable period of time and in terminating her parental rights under § (c)(i).