Termination under § 19b(3)(c)(i); Children’s best interests

Concluding that § (c)(i) existed and the trial court did not err “by finding it was in the children’s best interests to terminate” respondent-mother’s parental rights, the court affirmed. It was undisputed that, by the time her “parental rights were terminated, more than 182 days had passed since the initial dispositional order. Furthermore, many of the conditions which led to the adjudication still existed by the time of termination, and there was no reasonable likelihood that they would be rectified in a reasonable time given the children’s age.” While she had “secured employment, her psychological evaluation indicated no mental health disorders, and the record [was] inconsistent on the progression of her parenting skills, she continued to struggle with substance abuse and housing, which the trial court identified as the two most significant barriers at the outset of this case.” The court found that her “substance abuse was the most significant barrier to reunification of the family.” While she “showed some improvement, she also suffered setbacks and even relapsed, which apparently led to her decision to remove herself from the children’s lives for months.” Throughout the proceedings, she “presented a pattern of improvement followed by regression. By the time of the termination hearing, [she] had not been able to demonstrate consistent, lasting sobriety. Additionally, given her inconsistent behavior during the proceedings below, as well as the fact that [her] substance-abuse problem has lasted for ‘nearly a decade,’ [the court concluded] that the trial court did not clearly err when it found that [she] would not be able to rectify this barrier within a reasonable time given the children’s age.” It also found that respondent’s “unresolved homelessness was another barrier to reunification on which the trial court relied. At no point during this case did [she] procure independent, appropriate housing for herself and the children.” The record supported the trial court’s finding that she “had failed to rectify her housing barrier by the time of the termination hearing and that she would not be able to do so in a reasonable time given the children’s age.”