Termination under § 19b(3)(c)(i); Children’s best interests; Whether the factual record was complete or adequate

The court held that as to § (c)(i), “the record clearly and convincingly proved that there was no reasonable likelihood that respondent[-mother] would timely rectify her drug abuse and other barriers to reunification, and the trial court did not err by so finding.” Also, it saw “no error in the trial court’s determination that termination of respondent’s parental rights was in the children’s best interests.” Finally, her “lack of participation in her service plan or these child protective proceedings was not caused by her being improperly excluded or denied a meaningful opportunity, it was caused by her choice not to participate.” As to § (c)(i), “the conditions that led to the adjudication and that continued to exist as being respondent’s mental health, substance abuse, domestic violence, inadequate parenting skills, inadequate housing, and financial issues.” She did “not contest that these conditions continued to exist, nor does she dispute that more than 182 days elapsed between the issuance of an initial dispositional order and termination.” Rather, she argued “that the trial court erred by finding that there was no reasonable likelihood that she would rectify these conditions within a reasonable time considering the ages of the children.” Respondent claimed “that the trial court improperly focused on her problematic history, and not on the recent positive steps that she had made.” The court found that because “of her drug use, respondent never secured stable employment, which in turn prevented her from having her own transportation, led to utilities in her home being shut off, and led to her home being foreclosed upon for unpaid property taxes.” Despite her claim “that she has made recent progress toward rectifying the issues that led to the adjudication, she has not demonstrated any kind of meaningful and lasting progress.” Affirmed.