Termination under §§ 19b(3)(c)(i), (c)(ii), (g), & (j); In re Hudson; In re VanDalen; In re White; Child’s best interests; In re Olive/Metts Minors; In re Payne/Pumphrey/Fortson; In re Frey; Reasonable reunification efforts; In re Williams; In re Hicks; The Americans with Disabilities Act (42 USC § 12101 et seq.); Holmes v. Holmes; In re TK

The court held that the trial court properly terminated respondent-mother’s parental rights to the child where more than one statutory ground was established by clear and convincing evidence and it was in the child’s best interests. Also, the trial court did not err in finding that the DHHS made reasonable reunification efforts, and she did not show any plain error with the adequacy of the services to accommodate her mental health needs. As to § (c)(i), the trial court did not clearly err by finding that her “mental health issues and inability to control her anger were conditions that continued to exist. Similarly, the trial court did not clearly err when it found that a lack of stable housing and employment continued to be barriers to reunification. Respondent had recently become employed, but her history of employment was inconsistent throughout the entirety of the case.” She lived at five different locations while the case was pending and, “according to the caseworker, respondent’s housing was inappropriate for the child because of concerns identified in background checks of others living in her apartment.” The trial court also did not clearly err by finding that there was no reasonable likelihood she would be able to rectify these conditions within a reasonable time considering the child’s age. While she “made substantial progress with her substance abuse issues, she did not make significant progress in addressing all of the other barriers to reunification during the 22 months that the child was removed from her care.” The trial court’s finding focused on the evidence that she maintained a relationship with the father, despite the ongoing domestic violence between them. Respondent disputed this, but evidence was presented that the father’s car was seen at the same motel where respondent was staying, and she remained uncommitted about whether to remain married to him. The court further held that §§ (c)(ii) and (j) were established. As to § (g), respondent correctly noted that the trial court relied on the former version before it was amended. However, because the trial court’s decision was supported by other statutory grounds for termination, and it only was required to find one statutory ground, any error in either relying on or applying § (g) was harmless. Affirmed.