Termination under § 19b(3)(c)(i); In re Williams; Reasonable reunification efforts; A parent’s responsibility to engage in & benefit from the services offered by the DHHS; In re Fried; Accommodations for a parent’s disability; In re Hicks/Brown; Best interests of the children; In re White; Parent-child bond; In re Olive/Metts Minors
Holding that the trial court did not err by finding the DHHS made reasonable reunification efforts, that § (c)(i) was met, and that termination was in the children’s best interests, the court affirmed termination of respondents-parents’ parental rights. Their rights were terminated based primarily on substance abuse, mental health issues, and failure to maintain stable housing. On appeal, the court rejected their argument that the DHHS did not provide reasonable reunification efforts, noting they “failed to uphold their ‘commensurate responsibility’ to engage in and benefit from the services offered by” the DHHS. The court failed to see how they would have fared better if the DHHS had offered other services. It also rejected their claim that no statutory ground for termination existed, finding that § (c)(i) was established where “respondents had not accomplished any meaningful change in the condition that led to adjudication, i.e., their inability or unwillingness to properly care for the children.” The record supported that the condition leading “to adjudication continued to exist and there was no reasonable likelihood respondents would rectify it within a reasonable time.” Finally, the court rejected their claim that termination was not in the children’s best interests. “[T]he children’s bond with respondents was not healthy for the children, who desperately needed permanency and stability respondents could not provide.” In addition, respondents “failed to address their issues during the lengthy proceedings and were unable or unwilling to effectively parent the children.” And the children were doing well in their placements.
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