Child’s best interests

The court held that the “trial court did not fail to consider the relevant factors regarding [child-]CW’s best interests, and did not clearly err by concluding that termination of respondent[-father’s] parental rights was in the best interests of the child.” He claimed “that the trial court erred by determining that termination was in CW’s best interests because it did not consider factors relevant to the child’s best interests.” The court noted that “the trial court considered respondent’s failure to comply with the case service plan, and particularly respondent’s failure to address his substance abuse. Respondent briefly participated in inpatient substance abuse treatment, but left the program without completing it. Thereafter, he failed to participate in outpatient substance abuse treatment; although he reported that he attended NA weekly, he continued to test positive for” meth. Respondent “attended parenting time and appeared to have a bond with CW, but failed to participate in parenting education.” He also “reported having housing, but apparently moved three times during the year the child was in care.” He further “reported having employment, but failed to provide proof of employment or other source of income; at the time of the termination hearing, he was anticipating starting a job but did not have proof of that employment. The trial court considered that during the approximately 14 months that the child was in foster care, he had received needed medical and dental care, had started school and, through the help of the foster parents, was catching up on the delay in education. He was gaining confidence by playing sports and being part of a stable family.” The trial court also “considered the child’s need for stability and permanency, which the foster home provided, the child’s bond with the foster parents, and the foster parents’ willingness to adopt CW.”