Child’s best interests; In re Simpson; Parent-child bond; Permanency, stability, & finality; Foster care

Holding that termination was in the child’s best interests, the court affirmed termination of respondent-mother’s parental rights. Her rights were terminated under §§ 19b(3)(c)(i), (g), and (j) based on a variety of issues including neglect and trouble with housing and employment. On appeal, the court rejected her argument that termination was not in the child’s best interests. She claimed “the trial court gave inadequate weight to the parent-child bond and gave too much weight both to [the child’s] need for permanency, stability, and finality and to the advantages of foster care over respondent’s home.” However, the record reflected that “the trial court thoughtfully considered all the evidence relevant to these factors before rendering its findings.” It also reflected that the trial court’s “findings were amply supported by the evidence presented.” First, the record was “fully consistent” with the trial court’s finding that respondent and the child had a “weak” parent-child bond. Next, the record was consistent with the trial court’s determination that “although a residential placement was ‘never preferable to a home, whether it be a foster home or parent’s home,’ it nonetheless weighed in favor of termination here because respondent’s home was not appropriate for [the child] and would ‘only result in further trauma to her,’ and the residential placement was ‘really . . . the only hope at this point that she has.’” Lastly, as “to the advantages of foster care over respondent’s home, the caseworker testified that [the child] had been in 15 different placements throughout the case; that [she] had, unfortunately, been sexually assaulted in one of those placements; and that [she] was eventually placed in a residential facility to receive the treatment necessary to address her needs.” Overall, even if the trial court “erred in any of its findings regarding these factors, they [were] just three of many considerations relevant to a best-interests determination.”