In the Matter of the Welfare of the Children of: K. Y., Parent., A16-655

Mother (K.Y.) has five children; all were placed in foster care after she allowed a registered predatory offender contact with the children; mother admitted the allegation and children were adjudicated CHIPS.
Department developed a case plan: mental-health and parenting evaluations, follow recommendations, safe housing, group therapy for parents of sexually abused children, child therapy participation, and cooperation with guardian ad litem.
Department petitioned to terminate parental rights to three younger children; trial lasted ten days and included extensive evidence of mother’s long history with child-protection services and patterns of problematic parenting.
Testimony described a recurring pattern: mother is attentive to infants but delegates care to older children as they age; she associated with sexual predators and downplayed her children’s sexual-abuse histories.
Some service providers supported reunification (especially for the youngest child) if additional services/visits occurred; the district court found mother lacked insight and credibility and credited witnesses who described ongoing risks.
District court terminated parental rights on multiple statutory grounds, found the department made reasonable reunification efforts, and concluded termination was in the children’s best interests; appellate court affirmed.

Issue	Mother’s Argument	County’s Argument	Held
Whether termination relied on conditions existing at hearing	District court relied on past history, not present conditions	Court considered current conditions in context of history to predict permanency	Affirmed: court may consider history to project future inability; findings addressed present conditions in context
Whether department made reasonable efforts to reunify	Department failed to provide trauma-informed family therapy, coordinate providers, and denied visits	Department provided individualized, relevant, timely services; coordinated meetings and visits were offered	Affirmed: record supports finding of reasonable, meaningful efforts
Whether statutory grounds (failure to correct; palpable unfitness) were proved	Mother claimed compliance with services and current ability to parent	County emphasized persistent unsafe patterns, lack of insight, prior abuse exposure, and observed parenting deficits	Affirmed: clear-and-convincing evidence supported failure-to-correct and palpable-unfitness findings
Whether termination was in children’s best interests	Mother argued substantial evidence showed present ability to parent and preferred deferral for youngest child	County argued children needed stable, adoptive homes given prolonged out-of-home placement and mother’s lack of insight	Affirmed: district court’s best-interest findings supported by substantial evidence

Chosa v. County of Ramsey, 290 N.W.2d 766 (Minn. 1980) (termination findings must address conditions at time of hearing)
S.E.P. v. Commissioner of Human Services, 744 N.W.2d 381 (Minn. 2008) (elements required for termination and deference to district court)
J.K.T. v. County of Hennepin, 814 N.W.2d 76 (Minn. App. 2012) (reasonable efforts and present ability to parent are critical)
S.Z. v. State, 547 N.W.2d 886 (Minn. 1996) (court may project permanency by considering history)
P.R.L. v. County of Hennepin, 622 N.W.2d 538 (Minn. 2001) (conditions must continue for prolonged, indeterminate period)
J.R.B. v. County of Dakota, 805 N.W.2d 895 (Minn. App. 2011) (review standards for factual findings and abuse of discretion)
T.A.A. v. County of Ramsey, 702 N.W.2d 703 (Minn. 2005) (failure to protect children can support palpable-unfitness finding)
S.W. v. County of Wright, 727 N.W.2d 144 (Minn. App. 2007) (reasonable efforts require genuine assistance tailored to problems)
D.L.D. v. County of Hennepin, 771 N.W.2d 538 (Minn. App. 2009) (deference to district court credibility determinations)
W.L.P. v. County of Scott, 678 N.W.2d 703 (Minn. App. 2004) (best-interests balancing framework)