Termination under §§ 19b(3)(c)(i) & (c)(ii); Failure to make meaningful change; In re Williams

Holding that §§ (c)(i) and (c)(ii) were met, the court affirmed termination of respondent-mother’s parental rights. Her rights were terminated on the basis of housing instability, substance use, and failure to comply with court-ordered services and treatment plans. On appeal, the court rejected her argument that a statutory ground for termination was not met. It noted that § (c)(i) was met as respondent “did not accomplish any meaningful change in her lack of adequate housing after more than two years, and there is no reasonable likelihood that the conditions would be rectified within a reasonable time considering the children’s ages.” It also found that § (c)(ii) was met as she “did not accomplish any meaningful change in the other conditions that existed, and there [was] no reasonable likelihood that the conditions would be rectified within a reasonable time considering the children’s ages.”