Child’s best interests; In re White; Consideration of relative placement; In re Olive/Metts; Parent-child bond

Holding that the trial court did not clearly err in finding that terminating respondent-father’s parental rights was in the child’s (JCS) best interests “due to JCS’s need for safety[,]” the court affirmed the termination order. Respondent asserted that the trial court clearly erred “because it failed to consider JCS’s placement with his mother. However, the trial court did explicitly consider” this placement in making its best-interest determination. It “stated, ‘So I wanted to put that on the record that the Court did consider placement with a relative. But ultimately decides that it’s in the best interest of the child to terminate.’ Thus, the trial court did not clearly err by concluding that, despite JCS’s placement with his mother, termination of respondent’s parental rights was in” JCS’s best interests. As to respondent’s claim about the bond between he and JCS, the trial court acknowledged JCS’s testimony “that he felt better not seeing respondent, he did not want to have contact with respondent, and he was trying to move forward and could do that better if he did not have contact with [him]. The trial court further acknowledged JCS’s testimony that respondent would ‘whoop’ JCS for no reason and” also sexually abused him. “The trial court stated that as a result of this abuse, JCS had seen multiple therapists, was diagnosed with PTSD, and was hospitalized four times. Thus, [it] clearly considered respondent’s relationship with JCS based on JCS’s testimony, which demonstrated that JCS had no interest in maintaining any sort of bond with respondent.”