In re C.C. (V.M. v. State), 2012 UT App 265

V.M. appeals termination of her parental rights to C.C.; the juvenile court found grounds for termination and proceeded to a best-interests determination.
Mother does not challenge the existence of grounds for termination, only whether termination was in C.C.’s best interests.
C.C. is approximately one year old and has resided primarily in a risk foster home; foster parents seek to adopt.
Mother completed a five-week trial home placement but relapsed and was discharged from residential treatment.
A prior period of supervised parenting showed some good skills, but ongoing substance abuse impeded parental capacity.
Mother did not attend the termination trial, either in person or by telephone, after receiving trial notice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is termination in C.C.’s best interests given the record?	State argues termination is in C.C.’s best interests.	Mother argues for maintaining parental rights or permanent custody instead of adoption.	Yes; termination is in C.C.’s best interests.

In re A.C.M., 2009 UT 30 (Utah Supreme Court, 2009) (best interests determination after grounds found in termination proceedings)
In re B.R., 2007 UT 82 (Utah Supreme Court, 2007) (high deference to juvenile court’s best interests finding in termination)