Children’s best interests

In these consolidated appeals, the court held that the trial court clearly erred by concluding that termination of respondent’s parental rights to RM was not in that child’s best interests. It also determined that the trial court did not clearly err when it determined “that termination of her rights was in JW1’s and JW2’s best interests.” As to RM, the court held that while respondent “participated in the preventative services, it is clear that she did not benefit from them. She did not learn to manage her anger issues.” Although the trial “court mentioned in passing that respondent had ‘a history of violent outbursts including the incident that brought this case to court,’ it did not consider in any meaningful way the implications of respondent’s inability to control her temper and the harm it caused to her children.” Had the trial “court properly balanced all the evidence before it, and given that evidence the weight it deserved, it would have been left with the inescapable conclusion that under no circumstance would RM benefit from a continued relationship with respondent.” Thus, the court was “left with a definite and firm conviction that a mistake has been made. More than a preponderance of the evidence favored termination of respondent’s parental rights to RM.” Therefore, it reversed in part the trial court’s order and remanded for entry of an order terminating her parental rights to RM. Next, she challenged the trial court’s finding that termination of her parental rights to JW1 and JW2 was in the children’s best interests. The record supported “a finding that respondent was not able to safely parent her children, and would not be able to do so within a reasonable time. By contrast, the children were thriving in their relative placement and their needs were being met. Termination of respondent’s parental rights was the best avenue for the children to achieve stability, permanency, and finality.” Affirmed in part, reversed in part, and remanded.