A.T. v. State (In Re C.T.), 2018 UT App 233

Mother is a minor who lived with her parents (Grandparents) and had been caregiver for younger siblings; she has a history of sexual abuse, early pregnancy, and HIV.
DCFS removed Mother and Child after safety concerns (suicidal threats, inadequate caregiving); both were placed in custody and later Mother returned to Grandparents while Child went to foster care.
Juvenile court ordered reunification services for Mother; Mother did not complete required services (therapy, medication compliance, peer parenting), and providers noted she lacked bonding and caregiving capacity.
The court briefly set permanent custody/guardianship with Grandparents as the primary permanency goal, but DCFS and the court found Grandparents unable to safely supervise Child because Mother remained unsupervised in the home and Grandparents had other issues (financial, household, allowing problematic relatives in home).
The juvenile court terminated Mother’s parental rights based on neglect/unfitness, found termination “strictly necessary,” and concluded adoption by foster parents was in Child’s best interest. Mother appealed only the best-interest/"strictly necessary" finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination was "strictly necessary" where family guardianship was available	Mother: court failed to fully explore/implement guardianship with Grandparents and DCFS should have provided more services to evaluate that option	State: court considered and briefly implemented guardianship as a permanency goal, then reasonably rejected it for well-articulated safety and supervision reasons	Court affirmed: juvenile court complied with In re B.T.B. by exploring guardianship, properly rejected it, and termination was in Child's best interest; DCFS was not required to provide additional services before termination.

In re A.C.M., 221 P.3d 185 (Utah 2009) (best-interest requirement and termination standards)
In re T.E., 266 P.3d 739 (Utah 2011) (two-step termination test: statutory grounds and best interests)
In re J.P., 648 P.2d 1364 (Utah 1982) (parent–child relationship as constitutionally protected)