Termination under § 19b(3)(c)(i); Children’s best interests; In re White; In re Olive/Metts; Reasonable reunification efforts; In re Frey; In re Hicks/Brown; Parent Agency Treatment Plans (PATP); Americans with Disabilities Act (ADA)

Holding that § (c)(i) was established as to both respondents, that termination was in the children’s best interests, and that reasonable reunification efforts were made, the court affirmed the termination order. Both respondents challenged the existence of a statutory ground for terminating their parental rights. It was “undisputed that more than 182 days had elapsed since the initial dispositional order in this case.” The conditions leading “to respondent-mother’s adjudication were [her] failure to protect her children by violating the established safety plan, her lack of parenting skills, and medical neglect.” The court concluded “the trial court did not clearly err by finding that the conditions that led to adjudication—including [her] violation of the safety plan and her lack of parenting skills—had not meaningfully changed and were unlikely to do so within a reasonable amount of time.” The conditions leading “to respondent-father’s adjudication were [his] parenting skills, lack of stable housing, violation of his probation, and inconsistent drug testing.” The court concluded his “noncompliance with the PATP justified termination of” his parental rights under § (c)(i). The mother also challenged whether terminating her rights was in the children’s best interests. While the trial court acknowledged she “was bonded with the children, [it] properly considered [her] compliance with her case service plan and the children’s need for permanency and stability.” The court found that given her “noncompliance with her case service plan, the trial court properly concluded that the children’s need for permanency and stability supported that termination was in their best interests.” She further argued that the trial court erred in determining the DHHS made reasonable reunification efforts. She asserted that “the DHHS failed to provide her with rent assistance despite her struggles with housing.” But the caseworker testified that she “was provided with housing resources, and [she] utilized Section 8 housing at the start of the case. Such external resources were sufficient to discharge the DHHS’s duty.” As to her reliance on Hicks/Brown, that case “requires the DHHS to adjust its services to accommodate a parent’s disability under the” ADA. She did not suggest “that her issues completing services resulted from a disability.”