Best-interest finding; Voluntariness of release

The court affirmed the trial court’s order terminating respondent-mother’s parental rights to her children pursuant to her release of parental rights. Her best-interest argument was without merit. She raised arguments pursuant to the Adoption Code, but this case was brought pursuant to the Juvenile Code. “Respondent’s decision to consent to the termination of [her] parental rights does not transfer the proceeding from the juvenile code to the adoption code.” The court held that the “trial court does not need to announce a statutory basis for termination when a party consents to termination pursuant to the juvenile code,” and it agreed “with a previous panel’s conclusion that there is ‘no reason why a trial court would be required to articulate a best-interest finding under the same circumstances.’” Also, the court had “no basis upon which to conclude that the release was not knowing or voluntary.” The court held that “the record offer[ed] no support for the conclusion that the release was not knowing and voluntary.” It found that the “trial court fully explained what parental rights are, what the release meant, and the permanent nature of the release. Nothing in the record suggest[ed] that respondent was in a state of emotional turmoil while releasing her rights. [She] stated she was not under the influence of any drugs that would impair her ability to decide. She stated she had reviewed the release forms with her attorney and had no questions.” She cited “a snippet of her psychological evaluation opining that she was prone to emotional decision making in support of her contention that the release was not knowing.” Respondent also argued “that her ‘symptoms of depression, paranoia, and cognitive anxiety’ render[ed] her unable to understand the ‘substantive facts’ of releasing her parental rights.” However, she offered “no explanation for how these psychological symptoms barred her from executing a voluntary release, and she has failed to overcome the evidence to the contrary.” She also suggested “that she was pressured by her trial counsel into releasing her parental rights. However, respondent affirmed multiple times that she had voluntarily released her parental rights, and there is nothing in the record that indicates any pressure from [her] attorney.”