Reunification efforts; Abandonment & waiver; In re Hudson; Best interests; In re Gonzales/Martinez; Anticipatory neglect; In re Mota

The court held that respondent-mother abandoned and waived any challenge to reunification efforts, and that the trial court did not err by finding termination of her parental rights was in child-CCMB’s best interests. The case arose after respondent drove a car she knew was in disrepair, without a license or insurance, while impaired by marijuana, and with her 6-year-old daughter and 4-year-old son unsecured (she left their booster seats in the trunk). After the brakes failed and the car crashed, the son was ejected and died. Respondent later entered a no-contest plea to jurisdiction and statutory grounds. On appeal, the court held that any reunification argument was abandoned because it was not included in the statement of questions presented and was supported by only a single undeveloped citation. The court next held that the issue was waived because, during the plea colloquy, the trial court told respondent that if termination did not occur after the best-interests hearing, it would then order her “to do certain things” before the child could be returned to her care, making clear that the next step was the best-interests hearing. On the best-interests issue, the court held that although the record showed a bond between respondent and CCMB, that factor was outweighed by respondent’s poor parenting judgment and the danger she posed to the child’s safety. The court also held that any reliance on anticipatory neglect was proper because CCMB herself had been placed at the same risk as her brother, and the neglect did not depend on any difference between the children. Affirmed.