§ 19b(3)(c)(i); Child’s best interests

Concluding that § (c)(i) existed and the trial court did not clearly err by finding that termination of respondent-mother’s parental rights was in her child's (IL) best interests, the court affirmed. She argued “that she was not given sufficient opportunity to correct her deficiencies and behavior, suggesting that the trial court therefore clearly erred by finding that a statutory ground for terminating her parental rights was proven by clear and convincing evidence.” The court held that the record supported the trial court’s findings that the 182 day requirement of § (c) “was satisfied, the conditions that led to adjudication continued to exist, and there was no reasonable likelihood that the conditions would be rectified within a reasonable time considering IL’s age. The conditions that led to adjudication were the physical abuse of IL, the lack of insight regarding IL’s needs, the inability to understand IL’s cues, and the inability to communicate effectively with IL.” While the mother participated in “services, she failed to demonstrate any benefit from them so as to rectify the conditions that led to adjudication.” The caseworkers and service providers frequently had to intervene during her parenting time to ensure that IL was safe. Despite regular reminders from service providers, she “was often unable to understand what IL needed and wanted, or recognize when a situation was unsafe for IL.” The court noted that the mother “also repeatedly ignored or dismissed service providers’ redirection on how to meet IL’s needs or appropriately act around him.” The DHHS had not allowed her “to have unsupervised parenting time with IL since IL’s removal.” Also, her “psychological evaluation indicated that she was prone to engaging in high-risk relationships and could not provide safety for IL while he was in the care of respondent-father, who the psychologist had determined could not function as a safe parent. Further, even after months of intensive services, respondent-mother’s Infant Mental Health specialist could not determine whether additional time would improve” the mother’s parenting skills. The court held that the “trial court did not clearly err by concluding that there was no reasonable likelihood that [she] would rectify the conditions that led to adjudication within a reasonable time.”