Termination under §§ 19b(3)(c)(i) & (j); Reasonable reunification efforts

Concluding that § (j) existed and reasonable reunification efforts were made, the court affirmed termination of respondent-mother’s parental right to the child. She did not insist that she had a bond with the child, but instead focused on the causes of that weak bond. Although respondent contended the weak bond resulted from issues beyond her control, the reasons for the weak bond were “immaterial to the analysis of the trial court’s decision that termination was warranted under” § (j). However, “the trial court clearly erred when it found that the conditions that led to adjudication had not been rectified and that termination of respondent’s parental rights was justifiable under” § (c)(i). Nevertheless, because the court affirmed the trial court’s decision that termination was appropriate under § (j), the fact that the trial court erred when it held that termination was appropriate under § (c)(i) did not require reversal. Respondent also argued “DHHS failed to make reasonable efforts because it did not provide individual psychiatric therapy. Respondent claims that individual psychiatric therapy would have helped her with her tendency to ‘close down’ when being observed and instructed during parenting-time visits.” But she ignored the extensive efforts DHHS “made to rectify that precise issue, which included weekly meetings with caseworkers, conducting a bonding assessment, and referrals for mental and emotional therapy opportunities. Respondent was referred to multiple trauma-focused therapy services that were aimed at helping her open up.” In addition, when DHHS became aware of her “cognitive impairment, extensive efforts were made to accommodate that impairment and to ensure that the services were adjusted in a way that made them easier for respondent to understand.” Thus, DHHS’s efforts “were, at the very least, reasonable, so the trial court did not clearly err in making that determination.”