Reasonable reunification efforts; Accommodating a respondent’s psychological & mental-health disabilities; In re Hicks/Brown; Credibility; Child’s best interests; In re Mota

The court held that (1) the DHHS fulfilled “its duty to provide adequate reunification services that reasonably accommodated” respondent-mother’s mental-health disabilities and (2) the record showed that terminating her parental rights was in the child’s best interests. Thus, it affirmed the termination order. She did not challenge the statutory grounds for termination. Rather, she argued the DHHS failed to make reasonable reunification efforts “because its employees failed to sufficiently assist her in obtaining suitable housing in light of her psychological and mental-health disabilities.” The court disagreed, finding that the record showed the “DHHS made sufficient efforts to assist respondent in obtaining suitable housing, but that [she] failed to follow through with referrals and otherwise failed to take advantage of the services provided to her.” The DHHS knew that she “suffered from several mental-health disabilities.” But the record did not support her claim that it “failed to provide her adequate, specialized housing assistance in light of” those disabilities. A foster-care worker (L) “testified that she provided [her] numerous housing-related resources, including sending her applications for housing commissions and waiting lists for Section 8 housing. When respondent expressed that she needed additional help, [L] personally helped [her] to the extent that she was able to do so and thereafter provided her phone numbers for resource providers who could give her more in-depth, individualized assistance. There is no indication that respondent contacted the resource providers.” L further testified that respondent’s assigned parent partner (E) “provided respondent housing-related resources and helped [her] obtain personal identification documents necessary to apply for housing.” But according to E, “respondent did not follow through with the housing resources provided to her.” As to the child’s best interests, the record showed that her “parenting ability was poor despite her participation in numerous parenting-related services.” In addition, the DHHS presented evidence of the child’s “need for permanency, stability, and finality[,]” and there were several advantages to her “foster home, as opposed to respondent’s home.” While the record showed respondent had a bond with the child, “considering the best-interest factors outlined in Mota, the” facts of this case “weighed in favor of termination despite the bond.”