Children’s best interests; In re White

Holding that the trial court did not clearly err in finding that terminating respondent-mother’s parental rights was in the children’s best interests, the court affirmed the termination order. The record showed that she had a bond with each child. But “her inconsistent participation in services and ongoing mental-health issues prevented her from providing [them] with the care that they needed.” Two of them “had mental-health issues stemming from trauma sustained in [her] care, and the youngest child had been diagnosed with autism. The children’s needs—including their mental-health needs—were being met by their foster parents, they were bonded with their foster parents, and their foster parents were willing to adopt them.” The trial court repeatedly noted “that each child needed permanency, stability, and finality. Respondent could not meet those needs. She was rude and combative with the caseworkers, law-enforcement had to be called in response to her behavior, and [she] consistently tested positive for marijuana even though it negatively impacted her psychiatric medications.” She admitted “she was ‘triggered’ whenever she was ‘cut off’ or ‘treated unfairly.’ Her psychologist testified that respondent’s mental-health disorder meant that [she] had a ‘low tolerance for frustration,’ which would cause her to ‘lash out’ at others, including children.”