Termination under § 19b(3)(c)(i); In re White; Principle that only one statutory ground must be established; In re Ellis; In re Foster; Child’s best interests; In re Olive/Metts Minors; In re Moss Minors; Abandoning an issue by failing to properly address its merits; Woods v. SLB Prop. Mgmt., LLC

Holding that § (c)(i) existed and that termination was in the child’s best interests, the court affirmed the order terminating respondent-mother’s parental rights. The conditions leading to the adjudication were allegations of sexual abuse committed against the child. “Respondent admitted that she voluntarily released her parental rights to another child years before under similar circumstances.” She continued to have the same issues. In both cases, she “did not accept any responsibility for her actions and denied wrongdoing with either child. The trial court specifically noted that while respondent went through the motions of attending services offered to her, she failed to benefit from the services provided and continued to state that she did not believe she needed them. Respondent also stated that she did not understand why she was being told to participate in the services offered to her.” Further, the child showed “sexually charged inappropriate behavior towards” her throughout the investigation. The trial court found that it was learned from respondent given that, although the child was 11 years old, “he functions at an 8-year-old level. When confronted about the situation, respondent would become agitated and try to justify the behavior.” The court noted that her behavior and interactions with the child “did improve after she began participating in services, but [the child] continued to act inappropriately towards respondent . . . .” The trial court specifically determined that “barriers to reunification—inadequate parenting skills, sexual abuse, and emotional stability—continued to exist and there was no reasonable expectation that these issues would be rectified within a reasonable time, taking into consideration the child’s age.” The court was “not definitely and firmly convinced” it erred in this finding. As respondent failed to develop her argument as to the child’s best interests, the court deemed it abandoned.