In the Interest of T. A., 331 Ga. App. 92

T.A., age 3 when removed (June 2011), was adjudicated deprived after mother abandoned him and allegations of physical abuse, neglect, and lack of supervision. DFCS received temporary legal custody and later permanent deprivation findings.
DFCS required a case plan: parental-skills training, parent aide, therapy, regular visits, stable housing, and stable income. Mother completed most plan tasks except adequate housing.
Mother has an IQ of 56 (mild intellectual disability) and mild depression; evaluators concluded she would need 24-hour in‑home support to parent safely and could not independently manage a child with T.A.’s needs.
T.A. shows signs on the autism spectrum (communication deficits, repetitive behaviors, tantrums, abnormal lack of fear) and requires high structure, routine, and a parent able to manage appointments, special education, and therapeutic strategies.
Evidence showed mother’s parenting remained unsafe: needed constant reminders, failed to react when T.A. almost ran into the street, visits caused regression, and she had previously lost custody of another child. DFCS petitioned to terminate parental rights; juvenile court granted termination.

Issue	Mother’s Argument	DFCS/Appellee’s Argument	Held
Whether deprivation cause will likely continue	Mother: She largely completed the case plan; specialized training lacking, so deprivation not likely to continue	DFCS: Mother’s severe cognitive deficits prevent her from independently using case plan gains; would need constant in‑home support DFCS need not provide	Court: Held deprivation likely to continue — mother cannot parent T.A. independently despite case plan completion
Whether continued deprivation will likely cause serious harm	Mother: No evidence of harmful bond loss or that foster placement harms T.A.; visits not shown to be detrimental long‑term	DFCS: Prolonged/unstable foster care risks attachment disorder and developmental harm; T.A. needs stability and was regressing after visits	Court: Held continued deprivation likely to cause serious physical/mental/emotional harm given T.A.’s needs and foster‑care instability
Whether termination is in best interest (implicit)	Mother: Completion of case plan shows ability/improvement; specialized services should have been provided	DFCS: Best interest favors termination to achieve permanency and stability for T.A.	Court: Termination affirmed as in child’s best interest given risks of continued deprivation and mother's inability to parent alone

In the Interest of C. M., 325 Ga. App. 869 (recognizing deference to juvenile court factfinding in termination review)
In the Interest of H. F. G., 281 Ga. App. 22 (parental intellectual limitations may support termination where in‑home support is required but not provided)
In the Interest of A. R., 302 Ga. App. 702 (test asks whether parent, ultimately alone, can master necessary parenting skills)
In the Interest of S. L. B., 265 Ga. App. 684 (past loss of custody can indicate inability to parent current child)
In the Interest of R. D. B., 282 Ga. App. 628 (court may consider adverse effects of prolonged foster care in harm analysis)
In the Interest of C. T. M., 278 Ga. App. 297 (children need permanence and emotional stability; lack thereof can cause serious emotional problems)
In the Interest of A. T., 271 Ga. App. 470 (value of expert testimony on importance of permanency/stability for child’s well‑being)