E.W.G. v. Dent County Juvenile Office, 399 S.W.3d 48

E.W.G. appeals termination of parental rights to T.D.G., A.D.G., and M.A.G.; J.L.G.’s parental rights were not at issue for E.W.G. because he is not J.L.G.’s biological father.
The trial court assumed jurisdiction over all four children in 2010 due to alleged abuse by E.W.G. and placed them in the Missouri Children’s Division’s custody.
E.W.G. was charged with multiple child-abuse and domestic-assault offenses in April 2010 after abuse allegations by the children.
A service agreement with the Children’s Division required E.W.G. to complete multiple rehabilitative steps, including psychological evaluations, counseling, and supervised visitation.
E.W.G. pled guilty in Iowa and Missouri to two counts of child abuse in 2010, resulting in imprisonment and probation with no contact orders regarding J.L.G. and T.D.G.
The trial court terminated E.W.G.’s parental rights in March 2012, found abuse/neglect, and the court’s judgment was affirmed on appeal; issues concerning preservation of errors related to statutorily required findings were raised but deemed not preserved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court’s error for failing to make statutorily required findings is preserved.	E.W.G.—claims missing statutorily required findings.	Juvenile Office—preservation failed by E.W.G.	Not preserved; claims denied.
Whether there was clear, cogent, and convincing evidence to terminate rights based on abuse and neglect.	E.W.G. argues no link to future danger.	Court properly linked past abuse to ongoing risk.	Supported; termination affirmed.
Whether the court properly relied on service agreement and prior pleadings to predict future risk.	E.W.G. argues insufficient consideration of future risk.	Court found service agreement and probation showed ongoing risk.	Yes; evidence supported termination.

Murphy v. Carron, 536 S.W.2d 30 (Mo. banc 1976) (standard for review of termination decisions)
In re C.A.M., 282 S.W.3d 398 (Mo.App. S.D.2009) (deference to juvenile court findings; light most favorable to judgment)
In re S.M.B., Jr., 254 S.W.3d 214 (Mo.App. S.D.2008) (substantial evidence standard; termination appellate standard)
In re N.J.S., 276 S.W.3d 397 (Mo.App. E.D.2009) (clear, cogent, and convincing evidence required)
In re A.M.F. and D.R.F., 140 S.W.3d 201 (Mo.App. S.D.2004) (two-step termination; burdens of proof)
In re K.A.W., 133 S.W.3d 1 (Mo. banc 2004) (past conduct can support termination if linked to future risk)
In re D.O., 315 S.W.3d 406 (Mo.App. S.D.2010) (parent’s prior conduct and treatment efforts inform likelihood of future care)
In re T.M.E., 169 S.W.3d 581 (Mo.App. W.D.2005) (public policy against returning severely abused child to parent)
In re L.M., 212 S.W.3d 177 (Mo.App. S.D.2007) (two-step termination and best interest considerations)