In re C.H. (C.C. v. State), 2014 UT App 261

Mother appealed the juvenile court's order terminating her parental rights to C.H.
C.H. was removed in August 2013 and had lived in the same out-of-home placement for roughly one-third of his life by the time of the termination hearing.
The juvenile court found multiple statutory grounds for termination: abandonment; unfit/incompetent parenting; substantial neglect or unwillingness to remedy circumstances leading to out-of-home placement with a likelihood of continued inability to parent; failure in parental adjustment; and lack of serious effort to support or communicate with the child.
The court also found termination was in C.H.’s best interests: he was bonded with the foster family, well cared for, and the foster parents sought to adopt.
The Division of Child and Family Services (DCFS) made reasonable reunification efforts that were unsuccessful.
On appeal, Mother did not challenge several of the termination-ground findings (e.g., abandonment and failure in parental adjustment); she contested the best-interests findings but failed to show they lacked support in the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination was supported by statutory grounds	Mother argued the court erred in finding grounds (challenge focused on best interests; did not contest some grounds)	State/DCFS argued evidence supported multiple statutory grounds (abandonment, unfitness, neglect, etc.)	Affirmed: unchallenged grounds alone suffice; evidence supports termination grounds
Whether the juvenile court’s factual findings were clearly erroneous	Mother argued the findings (including best interests) lacked adequate support	State argued findings were supported by record and not clearly erroneous	Affirmed: standard is clearly erroneous; record supports findings
Whether termination was in the child’s best interests	Mother contested best-interests determination	State/DCFS pointed to child’s integration, bonding, care in foster home, and adoptive plans	Affirmed: best interests supported by evidence of bonding and stability
Whether DCFS made reasonable reunification efforts	Mother implied insufficiency of efforts	DCFS contended it made reasonable but unsuccessful reunification attempts	Affirmed: court found DCFS made reasonable efforts without success

In re B.R., 171 P.3d 435 (2007 UT 82) (appellate review does not reweigh evidence when a foundation for the court’s decision exists)
In re E.R., 21 P.3d 680 (2001 UT App 66) (factual findings reviewed under the clearly erroneous standard)