Termination under §§ 19b(3)(g), (j), & (k)(iii); Anticipatory neglect doctrine; Children’s best interests; Relative placement

The court held that §§ (g), (j), and (k)(iii) existed as to respondent-mother, and the trial court did not err in finding that terminating her parental rights was in her children’s best interests. Also, the trial court properly “terminated respondent-father’s parental rights under the same statutory grounds it relied on to terminate” the mother’s parental rights. Finally, the court concluded that the DHHS complied with its statutory obligations to explore relative placement. In challenging the existence of statutory grounds to terminate her parental rights to her children, AB, TV, CV, and JV, respondent only argued “there was no evidence implicating her in any abuse of the children.” But her argument was “belied by the extensive record in this case, and is devoid of legal merit.” The court noted that “it was not necessary for DHHS to establish that she herself had physically abused her children.” The evidence established that the mother allowed the father “to severely physically abuse a child in the home, exposed other children in the home to the violent assaults, and severely neglected the children by permitting them to live in almost unimaginable filth.” In addition, she “was complicit in keeping [the] father’s abuse from being discovered, and failed to cooperate with the investigation and medical treatment when the abuse of AB came to light. From this record, the trial court did not clearly err by concluding that the children would be harmed if returned to [her] care and custody, warranting the termination of her parental rights.” The father argued that the trial “court improperly relied on the anticipatory neglect doctrine to find statutory grounds to terminate his parental rights to TV, CV, and JV.” Contrary to his assertion, the evidence did not show that he treated his stepson-AB “differently than his biological children because of the lack of biological relation. Accordingly, the trial court did not err when it applied the anticipatory neglect doctrine to find that there existed statutory grounds to terminate [his] parental rights to his biological children.” The court held that in “any event, there was significant evidence presented that [the] father emotionally harmed and severely neglected TV and CV.” Similarly, it found that “the trial court could have inferred that JV would suffer this same harm based on the treatment of his siblings.” Affirmed.