DCPP VS. N.R.IN THE MATTER OF THE GUARDIANSHIP OF A.R. (FG-12-0096-16, MIDDLESEX COUNTY AND STATEWIDE)(RECORD IMPOUNDED), A-0804-16T3

Division sought guardianship of A.R., born 2010, terminating N.R.'s parental rights; judgment issued Oct. 30, 2015.
N.R. has long-term substance abuse with limited compliance and unstable housing.
A.R. was born with opiate exposure; she required hospitalization and was removed from N.R.'s care.
Reunification attempts repeatedly failed due to N.R.'s ongoing substance abuse, medical neglect, and exposure to domestic violence.
Bonding evidence showed a strong, stable bond between A.R. and her foster parents, with a deficient, trauma-related bond between A.R. and N.R.
Experts uniformly found N.R. unable to safely parent A.R. now or in the foreseeable future; termination would not cause more harm than good.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Division met all four statutory prongs by clear and convincing evidence	Division satisfied the prongs based on persistent neglect and risk	N.R. argues insufficient proof of prongs	affirmed; all four prongs met by clear and convincing evidence

In re Guardianship of K.H.O., 161 N.J. 337 (1999) (standard for guardianship termination under N.J.S.A. 30:4C-15.1(a))
In re Guardianship of D.M.H., 161 N.J. 365 (1999) (focus on permanency and child’s best interests)
N.J. Div. of Youth & Family Servs. v. F.M., 211 N.J. 420 (2012) (comprehensive framework for four-prong analysis)
N.J. Div. of Youth & Family Servs. v. E.P., 196 N.J. 88 (2008) (reaffirmed best interests and permanency considerations)
N.J. Div. of Youth & Family Servs. v. A.W., 103 N.J. 591 (1986) (guardianship and permanency principles)