In re H.R., 291 P.3d 583

T.R. (birth mother) appeals a Yellowstone County district court order terminating her parental rights to H.R. and D.R.
Children were adjudicated as Youths in Need of Care in 2010; Department pursued termination in 2011, hearing held Feb. 9, 2012.
Treatment plan approved Sept. 27, 2010 targeted four goals and nine tasks addressing health, safety, and contact with children.
Court found the plan appropriate but that T.R. failed to comply with tasks including anger assessment, and maintaining contact with the children and CPS.
T.R. faced ongoing serious mental health issues; anticipated future residential care in Missouri with supervision and medication management if discharged.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the treatment plan appropriate for T.R.?	T.R. argues plan was not appropriate.	State asserts plan tailored to her issues.	Plan found appropriate.
Did clear and convincing evidence show noncompliance with the plan?	T.R. contends she complied or partially complied.	State shows specific noncompliance on multiple tasks.	Noncompliance proven for tasks 2, 6, and 7.
Were the findings on best interests supported by the record?	T.R. argues flexible time for change; best interests unknown.	Courts consider permanency and stability for the children.	Best interests supported termination.
Did the district court properly apply the statutory termination standard?	Challenge to evidence sufficiency and standard.	Standard requires likelihood of unfitness not changing; evidence supports.	No error; statutory factors satisfied.

In re J.J.L., 355 Mont. 23, 223 P.3d 921 (2010 MT 4) (abuse of discretion standard for termination)
In re D.B., 339 Mont. 240, 168 P.3d 691 (2007 MT 246) (clear error review of termination findings)
In re D.A., 344 Mont. 513, 189 P.3d 631 (2008 MT 247) (primary consideration is child’s best interests)
In re L.H., 336 Mont. 405, 154 P.3d 622 (2007 MT 70) (complete compliance required; partial not enough)