In re Interest of Hunter L. & Opie L., A-17-652, A-17-653

Mother Amber L. has twin boys born Aug. 2015; DHHS opened a voluntary case in Sept. 2015 for unsanitary home conditions; case closed Jan. 2016 after 30 days of cleanliness.
April 1, 2016: police find the home cluttered, unsanitary, with moldy food, animal feces, and medications; children removed and Amber later convicted of child neglect.
Children returned ~Sept. 2016; Oct. 13, 2016: Opie became strangled in a cord but was not seriously injured; officer noted clutter hindered timely response.
Nov. 19, 2016: officers again find unsanitary, cluttered conditions (old milk bottle, mashed food, limited safe sleeping/playing space); children removed again.
Psychological evaluation diagnosed Amber with hoarding disorder and borderline personality disorder; prognosis guarded/poor due to lack of insight and limited motivation; long-term treatment required.
DHHS caseworkers and therapists reported chronic failure to maintain a clean, sanitary home despite frequent visits and assistance; juvenile court terminated Amber’s parental rights under Neb. Rev. Stat. § 43-292 and found termination in the children’s best interests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory grounds under § 43-292 exist to terminate parental rights	State: Amber’s mental illness (hoarding + personality disorder) prevents discharge of parental duties and will persist for a prolonged indeterminate period	Amber: Evidence insufficient to prove statutory bases for termination	Court: Clear and convincing evidence supports termination under § 43-292(5) (unable to discharge parental responsibilities due to mental illness)
Whether termination is in children’s best interests	State: Chronic unsanitary/cluttered home stemming from Amber’s disorders endangers children’s development and safety; reunification unlikely in reasonable time	Amber: Termination not shown to be in children’s best interests (argues for reunification)	Court: Termination is in the children’s best interests given ongoing risk, lack of consistent improvement, and long-term prognosis

In re Interest of Nicole M., 287 Neb. 685 (discussing de novo review in juvenile cases)
In re Interest of Giavonna G., 23 Neb. App. 853 (holding one statutory ground is sufficient for termination)
In re Interest of Kendra M., 283 Neb. 1014 (best-interests requirement for termination)
In re Interest of Ty M. & Devon M., 265 Neb. 150 (unsanitary home as symptom of deeper parental inability; cannot be remedied simply by cleaning)
In re Interest of Shane L. et al., 21 Neb. App. 591 (children should not await uncertain parental rehabilitation)