Children’s best interests; In re Mota; Effect of a parent’s drug use; In re Moss; Guardianship alternative; In re Prepodnik; Relative placement; In re Olive/Metts Minors; Guardian ad litem (GAL)

Holding that the trial court did not clearly err in finding that termination was in the children’s best interests, the court affirmed the trial court’s order terminating respondent-mother’s parental rights. She did not challenge the existence of a statutory ground for termination. The court concluded the trial court did not err in its best-interests analysis given that the mother “continued to use drugs and did not have suitable and appropriate housing for the children even at the time of the termination hearing. The trial court acknowledged that [she] had a bond with the children, noting that she visited [them] regularly. The trial court also recognized that [she] showed that she could be a good parent when she maintained sobriety. But, as [it] observed, despite the bond with her children, [she] was unable to remain sober and drug-free, nor did she stop fighting with respondent-father in front of the children.” In addition, she was unable to provide them with the permanency and stability they needed. They “received DHHS services for half of their young lives, and their only extended periods of relative calm and stability were when they were in the care of their grandmother, who intends to adopt [them]. All reports indicated that the grandmother’s home is safe, loving, and appropriate, that the girls are strongly bonded with her, and that they are consistently well cared for in her home. [She] also has a track record of keeping [them] safe and away from both” respondents when they are using drugs. Further, “the foster-care worker and GAL agreed that the grandmother provided the girls with the love, support, and stability they needed.” As to the mother’s guardianship argument, “the trial court properly determined that it was not safe for the children to be returned to [the] mother’s care and that termination of her parental rights was in the children’s best interests. Therefore, a guardianship would not have been appropriate.” As to the effect of their relative placement, in light of “the extensive history of abuse of controlled substances, domestic violence, and housing instability,” the court could not find clear error in the trial court’s “best-interests ruling simply because the children had been placed with their grandmother.”