Termination under § 19b(3)(c)(i); Case-service plan (CSP)

Concluding that under the circumstances, the trial court did not err by finding that DHHS established § (c)(i) for terminating respondent-father’s parental rights to his daughter, NCS, the court affirmed. He argued that “he was not given the opportunity to demonstrate his willingness and ability to make the necessary changes.” He pointed “to his successful completion of anger-management classes and claims that he was not given time to use those new skills. NCS was removed from father’s care in [10/23]. The termination hearing took place in” 10/24. Thus, he “was given more than 182 days to rectify the conditions leading to NCS’s removal.” His claim “that he was not given enough time to rectify the conditions that led to NCS’s removal” was unavailing. He also “failed to abide by his CSP. [He] was released on bond in the child abuse case while the child protective proceedings were ongoing. As part of his bond conditions, father’s CSP required him to abstain from alcohol and drug use.” The trial court noted that, although he “completed a substance-abuse program, he continued to test positive for marijuana and alcohol.” Also, the record showed that he “did not complete parenting classes, refused to allow DHHS to conduct a home visit, and did not respond to referrals for a psychological evaluation.” Further, he “stated that he was participating in services only because his children got him in trouble.” Thus, the record showed that he “failed to fully benefit from reunification services and failed to acknowledge his responsibility for bringing NCS into DHHS’s care in the first instance.”