Termination under § 19b(3)(c)(i); Children’s best interests; Reasonable reunification efforts; Procedural & evidentiary errors

The court concluded that the trial court did not clearly err by finding § (c)(i) existed. Also, it did not err by concluding that termination was in child-WH’s best interests. However, the trial “court failed to meaningfully analyze [child-]MH’s specific circumstances.” The trial court did not err by finding that DHHS made reasonable efforts at reunification. Finally, respondent-mother had “not shown a procedural or evidentiary error requiring reversal of the trial court’s order terminating her parental rights.” As to § (c)(i), “more than 182 days elapsed since the issuance of the initial dispositional order.” The court noted that the “trial court did not find that mother lacked adequate housing or resources, but nevertheless determined that mother had not adequately rectified her issues with emotional instability and inadequate parenting skills.” As to “whether there was a ‘reasonable likelihood that the conditions would be rectified within a reasonable time considering the child’s age,’ the trial court observed that mother had not benefited from the most recent services offered, and had likewise not benefited from ‘11 years of service delivery.’” The trial “court further noted that mother had received every service that the child-welfare system had to offer. Both children had waited for nearly two years for mother to provide them a stable environment and were facing an extended trauma-informed therapy. In light of these circumstances, the trial court found that the children had an immediate need for stability and finality that mother could not provide. In light of the foregoing, the trial court did not clearly err by finding statutory grounds for termination under” § (c)(i). As to WH’s best interests, “the trial court properly considered numerous factors when making its best-interest determination regarding WH. It did not err by concluding that termination was in WH’s best interests.” However, the trial “court failed to meaningfully analyze MH’s specific circumstances[,]” constituting clear error. Thus, the court vacated “the portion of the order terminating mother’s parental rights as to MH.” Affirmed in part, vacated in part, and remanded.