Children’s best interests; In re White; Relative placement factor; In re Olive/Metts; In re Atchley; Parent-child bond; Substance abuse

The court held that termination of respondent-mother’s parental rights served the children’s best interests notwithstanding placement with the father. The children were removed because of improper supervision, neglect, and the mother’s severe substance-abuse issues. She attempted inpatient rehabilitation multiple times but did not successfully complete any program. At the termination hearing, the children were living with the father, who was participating in his service plan, but the trial court terminated the mother’s parental rights. On appeal, the court reiterated that “[t]he focus at the best-interest stage has always been on the child, not the parent,” and that while relative placement weighs against termination, it “is not dispositive.” It held that the trial court properly found termination was in the children’s best interests because the bond with the mother was “unhealthy,” the children struggled with the impact of her substance use, and her instability harmed them even if the father could provide day-to-day permanency. The record showed she “sporadically appeared” for visits, often tried to reschedule at the last minute, and had not seen the children for nearly nine months. Further, her substance abuse impaired her ability “‘to be present and participate,’” while she failed to complete services and address ongoing mental-health and substance-abuse barriers. It concluded the trial court did not err in finding that the trauma and instability attributable to the mother made termination in the children’s best interests. Affirmed.