DCPP VS. T.S.F. AND M.E.C.IN THE MATTER OF THE GUARDIANSHIP OF M.M.C.(FG-04-0142-16, CAMDEN COUNTY AND STATEWIDE)(RECORD IMPOUNDED)(CONSOLIDATED), A-0853-16T4/A-0994-16T4

Child (M.M.C., born 2005) was removed from parents' care at 18 months and remained in the Division's custody through the 2016 guardianship trial.
Longstanding Division involvement since 2005: Tracey (mother) had drug use, domestic violence, unstable housing, unemployment, incarcerations, and noncompliance with services; Mark (father) was incarcerated (40-year sentence for voluntary manslaughter since 2013), had no relationship with the child, and sought no services.
Multiple placements for the child failed (failed kinship legal guardianship, failed relative placement, and a foster mother who died in the child’s presence); the child has significant behavioral issues.
Division’s expert testimony was undisputed that the child is adoptable and that immediate freeing for a select-home adoption is her best chance for stability.
Trial court (Judge Axelrad) found by clear and convincing evidence that the Division satisfied all statutory prongs of N.J.S.A. 30:4C-15.1(a) and entered a judgment of guardianship terminating parental rights; this appeal challenges those findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prong 1: Division made reasonable efforts to provide services and reunify	Division: offered services over many years; parents failed to engage	Parents: challenged adequacy/effectiveness of services (Mark contested all prongs; Tracey did not contest prong 1 on appeal)	Court affirmed that reasonable efforts were made
Prong 2: Parents’ conduct/condition poses a danger to the child’s wellbeing	Division: long history of substance abuse, domestic violence, instability, incarcerations created ongoing risk	Parents: disputed that current conditions meet statutory threshold	Court held Division proved dangerous parental conditions by clear and convincing evidence
Prong 3: Likelihood likelihood of harm if child returned; inability/unwillingness to change	Division: parents failed to rectify conditions over 11+ years and declined services; Mark made no effort to parent	Parents: argued they could and would remedy conditions or that evidence was insufficient	Court held parents had not remedied conditions and risk of harm remained; prong proven
Prong 4: Termination/guardianship is necessary for child’s best interests and to allow adoption	Division: child needs stability; expert opined adoption likely and is child’s best hope	Parents: argued termination not necessary; urged preservation of parental rights	Court held guardianship termination was necessary and supported by the record

N.J. Div. of Youth & Family Servs. v. F.M., 211 N.J. 420 (2012) (standards for termination of parental rights and burdens of proof)
N.J. Div. of Youth & Family Servs. v. E.P., 196 N.J. 88 (2008) (interpretation of statutory prongs for guardianship/termination)
In re Guardianship of K.H.O., 161 N.J. 337 (1999) (parental fitness and child welfare analysis)
In re Guardianship of D.M.H., 161 N.J. 365 (1999) (parental unfitness and procedural considerations)
N.J. Div. of Youth & Family Servs. v. A.W., 103 N.J. 591 (1986) (framework for best-interest determinations)