Termination under § 19b(3)(c)(i); In re Frey; Failure to rectify housing conditions; Reasonable efforts

The court held that clear and convincing evidence supported termination of respondent-father’s parental rights under § (c)(i) because the condition leading to adjudication continued without reasonable likelihood of timely rectification. Respondent admitted jurisdiction based on lack of stable housing, and the trial court adopted a service plan requiring housing, assessments, counseling, and drug screening. More than 182 days later, respondent remained homeless, alternating between couch surfing, a homeless encampment, and sleeping outdoors. The panel emphasized that termination is proper when “the totality of the evidence amply supports that [the respondent] had not accomplished any meaningful change” and failed to benefit from services. The court noted repeated testimony that respondent did not follow through with referrals, failed to maintain contact, and did not clarify his living situation despite opportunities to do so. Addressing respondent’s argument that immigration and documentation barriers prevented compliance, the court explained that the record showed “significant efforts by petitioner to work with respondent,” and that those efforts were “hampered by respondent’s lack of communication and failure to follow through.” Because respondent was in essentially the same position at termination as at adjudication, the trial court did not err in finding no reasonable likelihood of rectification within a reasonable time. Affirmed.