Termination of parental rights; § 19b(3)(m)(i); Continuing parent-child relationship harmful; CSC I & II; Sexual abuse of sibling; Anticipatory neglect; Emotional harm; Best interests; Parent-child bond; Parenting ability; Adoption; Relative placement

The court held that termination of respondent-father’s parental rights was supported under § (m)(i) and that termination of both respondents’ parental rights was in the children’s best interests. The father was convicted of CSC I and CSC II after sexually assaulting his child’s (ERS) half-sibling (AMB), respondent-mother pled guilty to witness interference after trying to bribe AMB to change her testimony, and the trial court terminated the father’s rights to ERS and the mother’s rights to all four children. On appeal, the court found § (m)(i) supported termination of the father’s parental rights because he had the required CSC convictions and continuation of the parent-child relationship would harm ERS. The court rejected his claim that incarceration eliminated any risk, reasoning that he ignored emotional harm and that the trial court could consider “grooming behaviors during visits and conversations” even while he was incarcerated. It also applied anticipatory neglect because the father had been in AMB’s life for nearly 10 years, and his sexual abuse of AMB was “indicative of how he may treat ERS in the future.” As to the mother, the court found termination was in the children’s best interests because she protected the father, disbelieved and bribed AMB, violated court orders, and showed “a willingness to violate the law to protect the abuser of her child.” As to the father, his parenting ability was “criminally inadequate,” his bond with ERS was weak, and the foster placement offered stability and adoption. Affirmed.