Termination under § 19b(3)(c)(i); Continued conditions leading to adjudication; Failure to benefit from services; Parenting ability; Children’s best interests; Parent-child bond; Domestic violence; Children’s preferences; Relative placement; Permanency & stability; Parent-agency treatment plan (PATP)
The court held that clear and convincing evidence supported termination of respondent-father’s parental rights under § (c)(i) and that the trial court did not err in finding termination was in the children’s best interests. The conditions leading to adjudication included domestic violence and physical abuse, educational and environmental neglect, substance abuse, criminality, and prior CPS involvement. Although respondent largely complied with his PATP after the trial court initially declined to terminate his rights, the evidence showed that he did not benefit from the services. During parenting time, he failed to appropriately redirect the children, showed favoritism, yelled at them, and did not recognize or address their trauma. He also continued to minimize his role in their removal and denied domestic violence and physical abuse despite his criminal convictions and the children’s accounts. After approximately 22 months, respondent “had not demonstrated an ability to safely parent the children” or taken responsibility for the harm he caused, and there was no reasonable likelihood that the conditions would be rectified within a reasonable time. As to best interests, respondent’s parenting time was often inappropriate and harmful, one child did not want to return to his care, and all three had improved after removal. The trial court properly considered respondent’s extensive domestic-violence history and the children’s need for stability and permanency. Although one child was placed with a relative, the risk of harm outweighed that factor. Further, “any bond was outweighed by the children’s need for safety, permanency, and stability.” Affirmed.
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