Child’s best interests; Parent-agency agreement (PAA)

The court held that in light of respondent-father’s “history of violence, inconsistent engagement with his [PAA], and alcohol use,” the trial court did not err in finding that termination of his parental rights was in the child's (MRM) best interests. Respondent and MRM “had a bond, but it did not seem to be that of a parent and child. [His] parenting ability was questionable. He had taken MRM from supervised visits without DHHS’s permission, which does not show good decision-making skills or a regard for MRM’s safety.” Respondent also “struggled to meet MRM’s needs, such as providing appropriate food. Because of MRM’s special needs, respondent would likely need to spend more time and effort to meet MRM’s needs. Respondent did not appear willing to do this. Though he stated he thought he would be able to meet MRM’s needs, he did not demonstrate an ability to do so throughout the case and also claimed that he was unaware of MRM’s special needs.” The court noted that MRM “was doing well in his placement and was receiving services for his special needs. MRM’s placement indicated she was willing to adopt MRM, which would provide stability and a home with his sister. MRM’s placement is considered a relative because she adopted MRM’s sister.” MRM’s placement “weighed against the termination of respondent’s parental rights, which the trial court appropriately considered.” However, the court noted that “the trial court acknowledged this and still found that termination was in MRM’s best interests. In light of respondent’s history of violence, inconsistent engagement with his [PAA], and alcohol use,” the trial court did not “err in finding that termination of respondent’s parental rights was in MRM’s best interests.” Affirmed.