Termination under § 19b(3)(c)(i); Child’s best interests; In re Moss Minors; In re Hudson; In re Olive/Metts Minors; In re White

Holding that § (c)(i) was established, and that termination of respondent-father’s parental rights was in the child’s (T) best interests, the court affirmed. It noted that “182 or more days” had “elapsed since the issuance of an initial disposition order.” Turning to whether the trial court properly found that he failed to rectify the conditions that led to adjudication, the court held that based on the “evidence, the trial court did not clearly err when it found by clear and convincing evidence that respondent failed to rectify his housing issues that led to adjudication because respondent failed to obtain independent housing that permitted him to adequately care for” T. Respondent testified “that he was living in a two-bedroom home with his cousin and that he would share a room with” T. However, a foster care worker (K) “testified that she did not believe respondent lived there because when she went to evaluate the home, respondent’s possessions were not at the home, he did not have a bed, and respondent told [K] that he was sleeping on the couch.” The day before the termination trial, K “went to assess the home again, but respondent was not at the home even though he knew when [K] was to arrive. Respondent’s cousin did not answer the door for [K]. [K] further testified that respondent was not paying rent, and she was concerned that his cousin could tell him to leave the home and take” T with him. In addition to lack of housing, the trial court found that respondent also failed to provide proof of legal income. K “testified that respondent provided fraudulent proof of income on several occasions.” Also, K “testified that she saw a Facebook posting where respondent was seeking out someone to make check stubs for him. Respondent testified that he recently began a job that would allow him to provide financial support for [T], but he did not provide” K with proof. Finally, the trial court found that proper supervision of T remained an issue for respondent. K explained that respondent permitted T’s “mother to have contact with [T] on multiple occasions although her parental rights were terminated.” Further, when he was granted overnight visitation with T, social media showed T “not being properly supervised by respondent during gambling parties. In addition, in the month prior to trial, respondent missed several visits with” T.