Reasonable reunification efforts; Accommodations for disabilities; In re Hicks/Brown; Children’s best interests; In re Olive/Metts; Guardian ad litem (GAL)

The court held that the trial court did not clearly err in finding that the DHHS made reasonable reunification efforts and that terminating respondent-father’s parental rights was in the children’s best interests. He did not challenge the finding that a statutory ground supported termination. As to the reasonable reunification efforts issue, the trial court provided him with a GAL “to help him navigate the court process and the reunification process. Respondent also had a Pathways case manager to help him with medication management, case management, counseling, and paperwork.” He did not “assert what accommodations” for his mental-health challenges the DHHS should have made, or show “that he would have fared better in mitigating his barriers to reunification had any such accommodations been made.” The court also found that the record belied his arguments as to parenting time, noting that it revealed he “did not participate in the parenting time offered to him[.]” In addition, it supported the trial “court’s finding that respondent was provided with housing applications and assistance as a reasonable effort toward reunification.” The court further determined that a preponderance of evidence supported the trial court’s conclusion that termination was in each child’s best interests. It made findings as to each child, and as to all three children, it “looked to the advantages that [their] foster placement offered over” their return to respondent’s custody. The record supported its finding that they “were thriving under the foster parents’ care.” Allegations in the petitions supported its findings that the children had “witnessed violence between the parents in the household” and the court noted that while he asserted he was bonded with the children, the record evidence reflected the opposite. Affirmed.