Termination under § 19b(3)(c)(ii); In re Sanborn; Reasonable reunification efforts; Accommodations for a respondent’s learning disability; Children’s best interests; In re White; In re Atchley; Relative placement consideration; In re Olive/Metts

The court held that the DHHS made reasonable reunification efforts, that § (c)(ii) supported termination, and that terminating respondent-father’s parental rights was in his children’s best interests. Thus, it affirmed the termination order. It was clear from the record that his “parenting skills were the primary hurdle to reunification over the approximately three years of services provided.” Further, contrary to his claim on appeal, the record showed he “was given access to a plethora of services aimed at helping him overcome the barrier his parenting skills posed to reunification, many of which were provided to respondent one-on-one.” The court noted that he did not explain what made those services insufficient and did not “state what other accommodating services he believes should have been additionally provided[.]” As to the existence of § (c)(ii), respondent’s rights were terminated “over 1,000 days after the initial dispositional order[,]” and while jurisdiction was initially exercised on other grounds, it became clear that his “deficient parenting skills significantly affected his ability to safely and properly care for” the children. There “was a wealth of testimony and documentation to the effect that respondent was unable to adequately respond to [their] needs in a timely manner, which often raised safety concerns[.]” In addition, he “received recommendations to rectify his parenting-skills issues and failed to do so despite having a reasonable opportunity.” Finally, sufficient evidence supported the trial court’s finding that there was no reasonable likelihood that he would “rectify his parenting-skills issues within a reasonable time given” the children’s ages, in “light of the length of the provision of services without adequate improvement in respondent’s parenting skills[.]” The court also concluded that the trial court did not clearly err in finding that terminating his rights was in the children’s best interests, based on numerous factors.