Termination of Parental Rights

Holding that the trial court did not clearly err in concluding that terminating the respondent-mother's parental rights was in the minor child's best interests, the court affirmed the trial court's order terminating her parental rights. The evidence was undisputed that respondent had her parental rights to six other children terminated due to her inability to adequately address her substance abuse. She continued to abuse alcohol and marijuana after she became pregnant with the child at issue in this case. The child's premature birth and low birth weight were attributed to respondent's substance abuse. At the termination hearing, respondent was eager to share with the trial court that she independently entered an inpatient substance abuse treatment facility. "However, it was apparent from respondent's testimony that she had not truly acknowledged her substance abuse." She initially denied at the termination hearing that she used substances during her pregnancy, explaining that the marijuana in her system was caused by her exposure to secondhand smoke. Even when she eventually admitted to using drugs during her pregnancy, she asserted that she quit using a month before she prematurely delivered the child. "Because respondent still had not completely acknowledged the impact of her substance abuse, it was readily apparent that it would be a very long time before she would be able to demonstrate an ability to sustain a substance-free lifestyle." The court concluded that this determination was "bolstered by the report from respondent's Clinic for Child Study evaluation." While the clinician acknowledged that respondent seemed to have some insight about her addiction and recently participated in a substance abuse program, he concluded that in light of her history, "it would take a considerable length of time" before she could show that she had "successfully addressed her longstanding personality issues and patterns of behavior." The clinician opined that it was not in "the child's best interests to wait that long for stability and permanence." The child, who was still being monitored for medical conditions related to the circumstances of her birth, required permanency and stability to foster her continued development and growth. Respondent was not in a position to provide that permanency and stability, "and it would be a very long time, if ever, before she would be able to demonstrate that she could properly parent her child."