Termination under § 19b(3)(c)(i); Reasonable reunification efforts; Child’s best interests

In these consolidated appeals, the court affirmed the trial court’s order terminating respondent-father’s parental rights to child-RS and respondent-mother’s parental rights to children-RS, HD, and CD. The father contended “that the trial court clearly erred by finding statutory grounds to terminate his parental rights when he substantially complied with his parent-agency treatment plan.” The court could not “say that the trial court clearly erred in determining that clear and convincing evidence established” § (c)(i) as a statutory basis for the termination of his parental rights. It further found that given the “record, the trial court did not plainly err by determining that DHHS met its obligation to accommodate respondent-mother’s cognitive and intellectual disabilities and, therefore, that DHHS’s efforts at reunification were reasonable under the circumstances.” Also, given the “facts, it was not clearly erroneous for the trial court to determine that termination of [the] mother’s parental rights was in RS’s best interests.” Further, the court found that “the trial court did not clearly err when it concluded that termination of [her] parental rights was in the children’s best interests.” Finally, under “these circumstances, and in light of the grounds for the trial court’s best-interest determination and ultimate ruling, respondent-mother has not shown a due process violation.”