In re E.Z.C., 370 Mont. 116

January 18, 2012, law enforcement found methamphetamine and paraphernalia in Mother's home; E.B.C. (3) and E.Z.C. were present, Father incarcerated.
Children were placed in foster care; emergency protective services and TLC were granted by the District Court after filing by the Department.
April 2, 2012, the Department petitioned to terminate parental rights and approved a permanency plan, alleging aggravated circumstances and no reunification requirement.
Adjudicatory hearing May 14, 2012 featured Poe’s testimony detailing dirty, unsafe living conditions, exposure to drugs, and E.B.C.’s positive meth test.
Dispositional hearing October 11, 2012 noted prior 2007 neglect incidents, worsening neglect, and Department conclusion that reunification plans were inappropriate; rights terminated.
Court found chronic abuse or chronic, severe neglect under § 41-3-423(2)(a), MCA, and terminated parental rights without reunification efforts or a treatment plan.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination without reunification was proper	Mother argues random incidents cannot prove chronic neglect.	Department argues ten-year pattern shows chronic, severe neglect justifying termination.	Termination without reunification affirmed.

In re A.J.W., 355 Mont. 264 (2010 MT) (standard for termination without reunification; clear and convincing evidence)
In re D.S., 329 Mont. 180 (2005 MT) (impacted chronic neglect analysis under aggravated circumstances)
In re M.N., 362 Mont. 186 (2011 MT) (defined chronic neglect by long duration and recurring severity)
In re T.W.F., 210 P.3d 174 (2009 MT) (standard of review for termination decisions; abuse of discretion)