Child’s best interests; In re Olive/Metts; Focus on the child rather than the parent; In re Mota

Holding that the trial court did not err in finding that terminating respondent-mother’s parental rights was in the child’s best interests, the court affirmed the termination order. She did not challenge the trial court’s finding of statutory grounds for termination. In challenging its best-interest determination, she suggested that she should have been given more “time to prove her sobriety.” But the court noted that, at this stage, the “focus must be on the child, not the parent.” The trial court, after thoroughly reviewing the evidence, determined by a preponderance of the evidence that termination was “in the child’s best interests. In making its ruling, [it] cited respondent’s disengagement from required services, her inability to bond with her child, her persistent struggles with substance abuse, and the child’s urgent need for permanence and stability. [It] also held that respondent was unlikely to successfully address her substance abuse issues within a reasonable timeframe, especially considering the child’s young age and the time spent in the relative placement’s care.” Despite the relative placement, the trial court concluded that “respondent’s lack of progress towards reunification and her ongoing substance abuse warranted the decision to terminate her parental rights. The record” showed that she “refused to participate in necessary psychological evaluations, neglected to complete a substance abuse assessment, continued to test positive for drugs, failed to secure housing or employment, engaged in criminal activity, and missed over 91 days of parenting time.” The court found no error in the trial court’s best-interest finding given “the child’s urgent need for stability alongside respondent’s substantial substance abuse problems and her neglect of the child[.]”