Termination under §§ 19b(3)(c)(i), (g), & (j); Principle that a trial court may not terminate a parent’s parental rights solely because the parent was a victim of domestic violence; In re Plump; Consideration of whether the parent’s own behaviors harmed the children or exposed them to harm; In re Jackisch/Stamm-Jackisch

Noting that the trial court did not expressly state the grounds on which it terminated respondent-mother’s parental rights, the court held that it clearly erred by finding “‘at least one’” of the grounds requested by the DHHS was supported by clear and convincing evidence. Her rights were terminated on the basis of substance abuse, domestic violence, and neglect. On appeal, the court found that the trial court erred by finding that a statutory ground for termination was met. As to § (c)(i), the record did not support that “mother’s own behaviors exposed the children to harm, [or] that the domestic violence existed and would continue.” As to § (g), “even without evidence of steady employment, the record does not indicate a failure to provide proper care or custody.” And as to § (j), the record was “devoid of evidence of physical harm to the children and while there [was] some record evidence of psychological harm, [it was] only as to the children observing the abuse of their mother, and the maternal aunt does not have them in therapy.” Reversed and remanded.