In the Interest of J. E., 309 Ga. App. 51

J. E. was deprived at birth after mother admitted cocaine use during pregnancy; custody placed with the Athens-Clarke County Department of Family and Children Services (the Department).
Mother repeatedly failed to achieve housing, steady employment, and compliance with the case plan, including drug treatment and random screenings; she tested positive for cocaine multiple times.
Mother cycled through shelters and programs, including outpatient and transitional housing, with intermittent visits to J. E.; she was not providing for child support.
A psychologist testified that the mother suffered from cocaine dependence with psychological dependence and that relapse risk remained high; evidence noted past and potential future harm.
Guardian ad litem and other witnesses reported that J. E. was thriving in foster care and that a continued noncustodial relationship with the mother was not in the child’s best interests.
The juvenile court found deprivation likely to continue and likely to cause serious harm, and held termination would be in J. E.’s best interests; the mother appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether deprivation is likely to continue and harm is likely	Mother argues deprivation may not continue or cause harm given current bond.	Department contends evidence shows ongoing deprivation and risk of relapse causing harm.	Yes; evidence supports continued deprivation and likely serious harm.
Whether present mother–child relationship invalidates termination	Mother asserts positive relationship weighs against termination.	State argues permanency and safety require termination despite bond.	No; permanency needs outweigh current bond in light of evidence.
Standard of review in termination cases	Appellant contends trial court’s findings were not clearly convincing.	State argues deference to trial court’s factual findings is proper when supported by evidence.	Yes; clear and convincing evidence supports termination under statute.
Best interests of the child	Mother claims continued relationship would benefit J. E. and provide stability.	Foster placement and permanency provide more stable home; continued deprivation remains in child’s best interests.	Yes; termination serves child’s physical, mental, emotional, and moral needs for permanence.

In re R. N., 224 Ga. App. 202 (1997) (appellate review standard for termination—defer to trial court)
In the Interest of A. R., 302 Ga. App. 702 (2010) (evidence of deprivation and future harm suffices for termination)
In the Interest of K. A. S., 279 Ga. App. 643 (2006) (lack of stable income/housing supports deprivation; ongoing harm potential)
In the Interest of M. N. R., 282 Ga. App. 46 (2006) (relapse evidence and drug treatment completion impact continuance finding)
In the Interest of J. T. W., 270 Ga. App. 26 (2004) (warning that deprivation alone does not prove harm; need specific harm evidence)
Santosky v. Kramer, 455 U.S. 745 (1982) (due process; clear and convincing standard; fundamental liberty interest)