Termination under § 19b(3)(c)(i); Parent-agency agreement (PAA)

Concluding that § (c)(i) was met and the trial court did not clearly err in holding respondent-mother failed to meaningfully change the conditions that led to the initial disposition, the court affirmed termination of her parental rights to the children. First, it was “undisputed that more than 182 days have passed since the initial dispositional order was entered in this case.” Next, the children were initially removed from her care because she “failed to provide proper care and support and her home was an unfit place for the children to live.” When the trial court terminated her “parental rights, there had not been a meaningful change to those conditions.” The court found that it “was reasonable for the trial court to believe that, given even more time, respondent would still not secure long-term housing for she had not shown motivation to find housing when she was being provided with support, let alone on her own.” Additionally, she “failed to meaningfully improve her ability to provide proper care and support,” or comply with her PAA. She “participated in, but did not complete, parenting education.” The court noted that magnifying “this difficultly is that the four children have special needs[.]” It found that raising “four children with special needs is undoubtedly difficult, but respondent’s lack of attendance at her children’s medical appointments and school meetings supports the trial court’s finding that she did not meaningfully improve her ability to provide proper care and support upon reunification.” Finally, she “waited until the final termination hearing to raise issues concerning the suitability of her children’s placements.” That delay further supported “the trial court’s decision, reflecting that she did not take proactive steps to protect her children if they were returned to her care.”