Child’s best interests; In re Gonzales/Martinez; In re White; In re Rippy; In re Olive/Metts Minors

Holding that the trial court did not clearly err in finding that terminating respondent-mother’s parental rights was in the best interests of the child at issue on appeal, the court affirmed the termination order. Respondent only appealed the order as to one of the children, and only challenged the trial court’s best-interests determination. The court found that the trial court’s statements indicated that it considered the child’s best interests individually. The child had “special needs involving his diagnoses for autism, post-traumatic stress disorder, and attention-deficit hyperactivity disorder.” The trial court also acknowledged the child’s “bond with respondent, but” additionally noted “the fact that respondent lacked housing, employment stability, and the parental capacity to provide for [the child’s] basic needs, let alone special needs, after two years.” The trial court further noted “that respondent had recently addressed her transportation issues by living in a city that provided a consistent bus system, but [it] still expressed concern over transportation for [the child] ‘if there was an emergency.’” In addition, it “acknowledged that respondent had her own trauma that she had to deal with in individual counseling and through the use of approximately 10 different medications for her mental health.” Thus, it found that she “struggled to take care of herself, much less” show that she could care for the child’s “special needs. In contrast, [his] placement—although not firmly determined to be permanent at the time of trial—was providing him with stability and consistency. CPS reported that [he] was doing well in his placement where his special and medical needs were being addressed by his foster parents and through services at his school, including speech and sensory therapy.” In light of “respondent’s inability to maintain employment, secure appropriate housing, and to consistently demonstrate the parenting skills necessary to care for” the child, the court found no clear error in the trial court’s best-interests ruling.