Termination under § 19b(3)(c)(i); In re Williams; Reasonable reunification efforts; In re Frey; Children’s best interests; In re Olive/Metts

Holding that (1) reasonable reunification efforts were made, (2) clear and convincing evidence supported termination under § (c)(i), and (3) terminating respondent-mother’s parental rights was in the children’s best interests, the court affirmed the termination order. It noted that respondent’s “service plan was created to address substance abuse, inappropriate supervision, and domestic violence. Her failure to consistently drug test or benefit from substance abuse treatment meant that the issue of substance abuse was left mostly unaddressed.” In addition, and perhaps due to “her absences from court hearings and treatment, respondent was not able to show that she benefited from the ordered services in which she did participate.” While she “participated in therapy, anger management, and parenting courses, she had not improved her ability to parent.” Further, the court concluded the trial court did not plainly err in finding that the DHHS provided reasonable modifications to respondent’s service plan “and she still did not fully comply with” it. As to § (c)(i), she “had over two years to remedy the conditions that led to adjudication: inappropriate supervision, substance abuse, and domestic violence. The evidence presented in the trial court supported a finding that there had not been a meaningful change in these conditions.” She tested positive for meth multiple times during the proceedings “and missed approximately half of her drug screens, each of which is considered a positive screen.” The court noted that at “the time of the initial petition, the main concern related to domestic violence was respondent’s violence against her family members. [She] participated in a domestic violence prevention course” but new concerns about domestic violence between her and the father of one of the children “arose. The police were called over 20 times regarding incidents between” the two from 8/22 to 12/23. Improper supervision also continued to be a concern. Finally, the “trial court appropriately considered the best interests of” the two children separately and “did not clearly err in finding that termination” was in each child’s best interests.