Children’s best interests; In re White; Post-traumatic stress disorder (PTSD)

Holding that the trial court did not clearly err in finding that terminating respondent-mother’s parental rights was in all her children’s best interests, the court affirmed the termination order. Throughout the case, she “struggled to comply with her treatment plan; she participated in about half of her required drug screenings, tested positive for illicit substances” at least seven times, did not “maintain adequate housing, and had inconsistent employment. [She] was also inconsistent with parenting time and struggled to appropriately parent her children during the visits she attended.” Three of them (RC, SA, and LA) “reported having regular nightmares about [her] and would often act out before visits because they did not want to participate in parenting time.” Due to her abuse, they “continued to exhibit extreme distress while in their foster care placements. They would scream and cry if their bedroom doors were closed or their caregivers” tried to bathe them. RC was diagnosed with PTSD. Only one child, MG, showed any kind of bond with respondent. The others “were bonded with their caregivers in their respective placements, and their placements were willing to adopt them and able to properly provide for them.” The court found these facts supported the trial court’s conclusion “that termination was in the children’s best interests. The trial court considered RC, SA, and LA as a group, finding they were similarly situated even though they were placed with different relatives.” It acknowledged that the “relative placements weighed against termination, but reasoned that [the] mother’s abuse, inability to parent her children, and failure to comply with her treatment plan or consistently attend parenting time clearly weighed in favor of termination.” It conducted a separate “analysis for MG because she was older and placed with her biological father. It acknowledged that MG could not be adopted because she was placed with her father, but, even with this placement, [it] was unconvinced that a custody or parenting-time arrangement . . . could adequately provide stability and safety for MG.” The record supported its findings as to all the children.