Termination under § 19b(3)(c)(i); Reasonable reunification efforts; In re Atchley; Children’s best interests; In re Sanborn; Parent-Agency Treatment Plan (PATP)

Holding that (1) termination was warranted under § (c)(i), (2) the DHHS made reasonable reunification efforts, and (3) termination was in the children’s best interests, the court affirmed the order terminating respondent-mother’s parental rights. The conditions leading to the adjudication “were (a) domestic violence, (b) an unfit home, (c) neglect, (d) improper supervision, and (e) respondent’s untreated mental health. Of importance during the proceedings, respondent never obtained suitable housing. [She] was unable to make ‘small down payment[s]’ or show ‘proof of income.’ She also never verified her employment status or income from any of her jobs and admitted she never secured her own housing despite referrals.” In addition, she “lacked the ability to properly parent her children because of unaddressed mental-health concerns and inability to supervise [them]. Despite receiving parenting classes, supportive visitation, a psychological evaluation, and therapy, respondent did not benefit from the services and instead was ‘often combative.’ True, she attended her parenting time sessions, but case workers had a ‘plethora of concerns in regards to the safety of the children.’” Further, the record did not indicate that she “could rectify the issues in a reasonable amount of time considering the children’s ages. When the trial court terminated respondent’s parental rights,” the children were 15, 7, 5, and 2 years old. Three of them had been out of her care since 12/20, and one was never in her care. The record did “not show respondent was able to rectify her ability to take proper care of the children in a reasonable amount of time.” As to reunification efforts, the record supported the trial court’s finding that the DHHS “made the necessary referrals to help respondent address the barriers to reunification with her children and that additional time to comply with her PATP was not necessary.” The court was not “persuaded that she was entitled to additional housing assistance and was not referred for more specialized parenting classes despite being willing to participate—the trial court appropriately concluded those would not have benefitted her because she demonstrated little to no benefit from the services already offered over several years.” As to the children’s best interests, they were “doing well in their respective placements and would be at risk of harm if returned to” her care.