Termination under §§ (c)(i), (g), & (j); Reasonable reunification efforts; Child’s best interests
Holding that the DHHS’s reunification efforts were reasonable, that §§ (c)(i), (g), and (j) were established, and that termination was in the child’s best interests, the court affirmed the order terminating respondent-mother’s parental rights. A foster care specialist “testified that respondent was provided numerous housing resources, including Section 8 information, Housing Commission information, and applications, but she never followed up with any of them. At the time of the termination hearing, respondent was living with a friend, had not allowed the home to be assessed, and had not requested any” further assistance. She was also provided “services to address her substance abuse issue, but she failed to either complete or benefit from” them. As to help with visitation, “during the period just before the termination hearing, respondent was given bus tickets and still did not attend visits.” The court concluded that she “was given a meaningful and adequate opportunity to participate in and benefit from services, but she failed to do so. Given her failure to fully take advantage of” those that were offered, she could not show she would have done better if others had been provided. As to statutory grounds for termination, “the conditions that brought the child into care were respondent’s substance abuse, lack of employment, and lack of housing. While respondent did obtain employment, she never secured stable housing or rectified her substance abuse problem, despite” the DHHS’s reasonable efforts. She “continued to miss screens, never completed substance abuse counseling, and had stopped trying to find suitable housing. Given the length of time that the child had been in care and respondent’s minimal progress, there was also no reasonable likelihood that the conditions would be rectified within a reasonable time considering the child’s age.” Finally, as to the child’s best interests, even if the trial court gave insufficient “weight to the bond between respondent and the child, that one factor does not outweigh the other factors that supported termination, including the child’s need for permanency, the foster parents’ ability to provide permanency, respondent’s lack of compliance with her service plan, respondent’s inconsistent visitation, the fact that the child was comfortable and safe in her foster home, and the possibility for adoption.”
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