Termination under §§ 19b(3)(c)(i), (g), & (j); Reasonable reunification efforts; Child’s best interests

Holding that the trial court properly found that §§ (c)(i), (g), and (j) existed, that reasonable efforts were made to reunify respondent-mother with the child, and that termination was in the child’s best interests, the court affirmed termination of her parental rights. The court initially noted that her argument on the issue of reunification consisted largely of a review of her history and mental health issues. She did “not significantly identify what additional efforts should have been made to seek reunification beyond a general assertion that a referral had not been made for services based upon the psychological evaluation.” But her support for this claim was “a statement by the guardian ad litem at a permanency planning hearing held four months before the termination hearing to the effect that respondent had recently taken part in a psychological evaluation and that the recommendations arising from that evaluation had not yet been put in place.” Further, the testimony of both foster care workers C and F “was that respondent did not take advantage of the services that had been offered.” Indeed, not only did F “testify that respondent failed to take advantage of the services that had been offered, [F] did not believe that there were any services that could be offered that would make a difference in this case. In light of this testimony, and respondent’s failure to identify any additional services that should have been provided,” the court was “not persuaded that there are any additional efforts that could have or should have been made to reunify respondent with the” child. As to the child’s best interests, while there appeared to be a good bond between them, given “the psychological evaluation, the poor prognosis in this case, and the need for permanency and stability,” the trial court did not clearly err in finding that termination was in the child’s best interests.