In re M.D. (C.L.D. v. State), 2014 UT App 225

C.D. (Father) appeals termination of his parental rights in M.D. and the order is affirmed.
The juvenile court found termination was in M.D.’s best interest despite no adoptive placement at trial.
Father is found unfit and likely to remain unfit due to cognitive limitations and lack of understanding of M.D.’s needs.
Visits with M.D. were not strongly bonding; M.D. showed agitation and resistance.
Court concluded termination and adoption remain the best and most likely outcome for M.D.; DCFS efforts deemed reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was termination in M.D.’s best interests?	Father argues no best-interest basis due to lack of adoptive placement.	Father contends stability and fiancée caretaking could work; not proven.	Yes; termination in child’s best interest supported by evidence.
Did DCFS make reasonable reunification efforts?	DCFS failed to adequately address Father’s cognitive limits.	DCFS conducted a broad, continued efforts including services.	Yes; court did not abuse discretion; efforts were reasonable.
Were Father’s cognitive limitations properly considered in unfitness finding?	Cognitive limits justify more services or different plan.	Cognitive limits indicate unfitness and need for separation.	Yes; cognitive limitations supported unfitness rather than need for more services.

In re E.R., 21 P.3d 680 (Utah App. 2001) (clear weight standard for juvenile findings of fact)
In re R.A.J., 991 P.2d 1118 (Utah App. 1999) (review of juvenile court findings; defer unless clearly preponderant)
In re B.R., 171 P.3d 435 (Utah 2007) (reweighing not allowed when foundation exists in evidence)
In re J.D., 257 P.3d 1062 (Utah App. 2011) (best-interest analysis includes impact on child; lack of adoptive placement not fatal)
In re A.C., 97 P.3d 706 (Utah App. 2004) (DCFS has broad discretion to determine reasonable reunification efforts)