In re J.P..., 502 P.3d 1247

Mother had two children: J.P. (b. 2013) and T.P. (b. 2016). J.P. has autism and a history of aggressive behavior toward T.P.
The family experienced domestic violence and abuse by Mother’s father (Grandfather); DCFS found physical abuse by Grandfather and later by Mother after incidents at a shelter.
The juvenile court adjudicated the children abused/neglected, set reunification as the initial goal, then discontinued services after an unsuccessful trial home placement; the State petitioned to terminate Mother’s parental rights.
The children were separated in foster care due to J.P.’s ongoing aggression toward T.P.; foster parents and evaluators reported safety concerns for T.P.
At trial Mother did not contest statutory grounds for termination but argued termination was not in the children’s best interest and that they should be returned together to her custody; she did not seek a long-term guardianship with relatives or foster families as an explicit alternative.
The juvenile court found six statutory grounds for termination, concluded termination was strictly necessary after considering kinship and nonrelative guardianship options, and ordered termination to permit adoption; Mother appealed the best-interest/strictly-necessary ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court failed to properly weigh sibling-bond preservation in the best-interest analysis	Mother: Court undervalued the harm to sibling bond from terminating her rights and should favor keeping siblings together	State: Court considered sibling bond but permissibly prioritized T.P.’s safety and need for permanency over keeping siblings together	Held: Court adequately considered sibling bond; separation was justified given J.P.’s documented aggression and safety risk to T.P.
Whether the court failed to consider long-term guardianship with nonrelatives as a feasible alternative (strictly necessary inquiry)	Mother: Court did not properly evaluate permanent guardianship with nonrelatives as an option short of termination	State: Court fulfilled its statutory duty to evaluate alternatives and reasonably rejected kinship and nonrelative guardianship based on evidence	Held: Court thoroughly considered kinship and nonrelative guardianship and permissibly concluded termination was strictly necessary for the children’s best interest and permanency

In re B.T.B., 472 P.3d 827 (2020) (explains "strictly necessary" requirement as part of best-interest analysis)
In re G.D., 491 P.3d 867 (2021) (sets standard for mixed question review of best-interest/feasibility findings)
In re J.M., 463 P.3d 66 (2020) (describes broad, deferential best-interest inquiry and appellate review standard)
In re H.F., 455 P.3d 1098 (2019) (lists non-exhaustive factors for best-interest determinations)
In re N.K., 461 P.3d 1116 (2020) (recites the two-step termination framework)
In re T.E., 266 P.3d 739 (2011) (discusses burden to prove statutory grounds for termination)
In re O.C., 127 P.3d 1286 (2005) (recognizes preference to keep siblings together where practicable)
In re B.R., 171 P.3d 435 (2007) (explains appellate courts should not reweigh evidence supporting a juvenile court’s factual findings)