Termination under § 19b(3)(c)(i); Child’s best interests
Concluding § (c)(i) existed and the trial court did not clearly err in holding that termination of respondent-father’s parental rights was in the child’s best interest, the court affirmed. “The primary condition that led to adjudication was respondent’s physical assault on the child, but other conditions were respondent’s failure to address the child’s medical issues and the child’s home environment.” While there was evidence he “had made some progress in therapy and shared a bond with the child, the trial court did not clearly err by finding that the evidence supported termination” under § (c)(i). The court determined that respondent “could not meet his minimum parental responsibilities, never progressed to unsupervised visits, failed to consent to the child’s medication, and did not have a suitable home for the child.” Considering his “general lack of progress and failure to benefit from services for over two years, the trial court also did not clearly err when it found that the conditions that led to adjudication were not reasonably likely to be rectified within a reasonable time considering the child’s age.” In addition, the court concluded delaying permanency for the child was not in the child’s best interests.
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