Department of Human Services v. C.L.C.

Evidence of irresponsibility, dishonesty, and instability that demonstrate a parent’s inability to provide proper care for his or her children over an extended period of time can be sufficient to show that the parent’s mental health issues were seriously detrimental to the children at the time of trial for the purposes of terminating parental rights.

Mother appealed a judgment terminating her parental rights to her three children on the grounds of unfitness. Mother asserted that her conduct or condition at the time of trial was not seriously detrimental to the children and that the record contained evidence showing she was a fit parent because she was engaged in services to treat mental health problems. The Court of Appeals considered evidence that mother consistently lied to DHS and the trial court about her living situation and progress in treatment; and the Court reasoned that her continued mental health problems, and lack of progress in treatment, made it unlikely that she would be able to provide adequate care to her special needs children. The Court held that mother’s continued mental health problems directly affected her ability to parent her children making it unlikely that the children could be integrated into mother’s home within a reasonable time. Affirmed.