Children’s best interests; In re Gonzales/Martinez; Consideration of relative placement

Holding that the trial court satisfied the requirement that it “consider relative placement in making its best-interest determination[,]” the court affirmed the order terminating respondent-mother’s parental rights. She asserted that it erred in finding that “termination was in the children’s best interests, because it failed to consider that [they] were placed with a relative.” The court disagreed, determining that the record showed “the trial court made extensive findings that demonstrate express consideration of the children’s placement with their relative-grandparents. . . . [It] explicitly considered that placement and the grandparents’ willingness to adopt the children when making its best-interest determination. It also considered whether guardianship would better serve the children’s best interests than adoption.” It concluded “that adoption was more supportive of the children’s best interests than a guardianship or returning [them] to respondent, primarily because the children needed permanency and a stable home environment. In fact, the trial court expressly stated that there was no evidence to indicate that guardianship ‘would create a better environment or encourage respondent . . . to be a healthy addition’ to the children’s lives. As long as a relative-placement consideration is not ‘wholly absent from the trial court’s best-interest determination,’ the trial court is not required to articulate specific ‘magic words’ for best interests.” The court found that the trial court here “more than adequately satisfied” the relative-placement consideration requirement.