Child’s best interests; In re Olive/Metts; Relative placement; In re Gonzales/Martinez; Guardianship; In re Lombard

The court held that the trial court did not err in finding termination was in the child’s best interests despite his relative placement. The child was born testing positive for multiple substances, including cocaine, meth, methadone, and opioids, and he remained hospitalized for more than six weeks with withdrawal symptoms. Respondent-mother admitted longstanding drug addiction, lack of prenatal care, no housing or employment plan, and a prior termination. On appeal, she only challenged the trial court’s best interests finding. The court held that the best-interest finding was supported by the lack of bond, the mother’s failure to provide for the child or be “part of the child’s life,” and her failure to address drug addiction. The court noted she had not visited the child while he was in the grandmother’s custody, was still using heroin and crack cocaine at the time of trial, and showed no signs of improvement. It rejected her reliance on relative placement because the trial court specifically considered that factor and still found termination appropriate. The child was thriving with his grandparents, bonded with his grandmother and half sibling, and the grandmother was willing to adopt. The court also found guardianship unnecessary because the child was too young for guardianship, adoption would provide permanency, and without termination “the child could be returned to [respondent], which would put the child at risk.” Affirmed.