In the Matter of the Welfare of the Children of: K. L. and D. L., Parents., A16-938

Infant J.L. (born Jan. 2015) suffered serious injuries at seven weeks: brain hemorrhage, facial bruising, and 16 healing rib fractures the pediatrician concluded were inflicted repeatedly.
Parents K.L. and D.L. gave implausible explanations; D.L. admitted episodes of extreme frustration while caring for the infant and once squeezed the child until an "audible grunt." K.L. acknowledged bruising and D.L.’s temper but did not protect the child.
Psychological and parenting evaluations diagnosed significant mental-health and attachment/parenting concerns for both parents; evaluators recommended individual and couples therapy and in‑home parenting work.
Parents’ participation in services was sporadic and yielded little progress; in‑home educator concluded return of children to parents’ care was inappropriate. Children were placed in foster care; A.L. (born Jan. 2016) never resided with parents.
County petitioned to terminate parental rights under multiple statutory grounds. After a three‑day trial, the district court found clear and convincing evidence supporting termination, that the county made reasonable reunification efforts, and that termination was in the children’s best interests. Appeal affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for statutory grounds (neglect duties)	K.L./D.L.: Evidence insufficient; they attended services and scheduled appointments	County: Serious inflicted injuries, parents failed to protect child and lacked insight; no meaningful progress	Court: Affirmed; clear and convincing evidence supports neglect ground — single ground sufficient for termination
County made reasonable efforts to reunify	K.L./D.L.: Missed therapy partly due to pregnancy and scheduling problems; were still working case plan	County: Provided services based on evaluations, timely and accessible, in‑home parenting, transport assistance	Court: Affirmed; district court’s findings on the six statutory factors supported reasonable efforts
Best interests of the children	K.L./D.L.: Parents love the children and argued emotional bonds should weigh against termination	County: Children are thriving in foster care; J.L. shows post‑visit distress; safety and stability prevail	Court: Affirmed; termination serves children’s paramount interest in safety/stability despite parents’ expressed love
Adequacy of district court findings on attachment/parental bond	K.L./D.L.: Court failed to make specific findings on children’s attachment and parents’ love	County: Court addressed parental love but emphasized failure to use services and ongoing risks	Court: Affirmed; court made findings sufficient to analyze best‑interests factors

In re Welfare of Children of S.E.P., 744 N.W.2d 381 (Minn. 2008) (standard for reviewing sufficiency of evidence and requiring at least one statutory ground plus best interests)
In re Welfare of R.W., 678 N.W.2d 49 (Minn. 2004) (one statutory ground plus best interests suffices to affirm termination)
In re Welfare of A.D., 535 N.W.2d 643 (Minn. 1995) (clear‑error standard for findings of statutory grounds)
In re Welfare of J.K., 374 N.W.2d 463 (Minn. App. 1985) (need showing parent presently unable/willing to assume responsibilities and neglect will continue)
Matter of Welfare of H.K., 455 N.W.2d 529 (Minn. App. 1990) (reasonable‑efforts requirement must be genuine assistance)
In re Welfare of R.T.B., 492 N.W.2d 1 (Minn. App. 1992) (three‑factor best‑interests balancing test)
In re Tanghe, 672 N.W.2d 623 (Minn. App. 2003) (district court must explain rationale for best‑interests finding)
In re Welfare of Child of W.L.P., 678 N.W.2d 703 (Minn. App. 2004) (findings need not be overly detailed)
In re Welfare of Children of J.R.B., 805 N.W.2d 895 (Minn. App. 2011) (abuse‑of‑discretion review of best‑interests determination)
In re Welfare of Child of D.L.D., 771 N.W.2d 538 (Minn. App. 2009) (termination inappropriate if not in child’s best interests)