Children’s best interests; Bond with the children; Lawyer-guardian ad litem (L-GAL); Relative placement

Concluding that the trial court did not clearly err by finding termination of respondent-father’s parental rights was in the best interests of his children, the court affirmed. He claimed that “he shared a bond with them, provided for their needs, and posed no threat to their well-being.” Yet, the trial court considered his “bond with the children, finding that respondent’s testimony regarding it was ‘sincere and truthful.’” However, it “also found that the bond did not outweigh the other best-interest factors.” Here, the record reflected that he “failed to consistently participate in court-ordered visitations. When he did participate, he used vulgar language around other young children and threatened staff. These actions reflect negatively on respondent’s parenting abilities and favor termination.” Also, he “failed to participate in individual therapy, parenting classes, or undergo a required psychological evaluation.” His refusal or “inability to complete these services indicates an unwillingness to take the steps necessary to ensure his children are adequately cared for.” Further, the trial court found that he “posed a risk to his children’s well-being because he sexually assaulted SG [a half-sister of two of the children], which outweighed any evidence that might have favored preserving his parental rights.” The court found that “the mere fact that respondent had not sexually assaulted his three daughters is not dispositive as to whether they were at risk of sexual assault in the future. In light of respondent’s sexual assault—which included penetration of SG—the [trial] court did not clearly err by finding that there was a risk of harm to the children.” Lastly, the court disagreed with the L-GAL’s “argument that the trial court failed to explicitly consider the children’s placement with relatives in its best-interest analysis, thereby requiring” remand. The court noted that because the trial “court expressly considered the relative placement, a remand for additional findings related to the placement is not required.”