In the Matter of the Welfare of the Children of: K. M. C. and D. S. W., Parents., A16-1076

Father (D.S.W.) pleaded guilty and was convicted of first-degree criminal sexual conduct for sexually assaulting an eight-year-old girl (J.C.) in 2014 while living in the home and supervising four children.
The two boys (E.W. and S.W.) are D.S.W.’s biological children and were present in the home during the offense; Washington County sought termination of his parental rights to those boys.
At the 2016 termination trial, social-worker and guardian ad litem testimony supported termination; the mother (K.M.C.) also opposed maintaining a relationship between the children and D.S.W.
District court found D.S.W. inflicted egregious harm (directly and indirectly), had a conviction that qualifies as a statutory ground for termination, engaged in domestic violence, denied the offense, and would be incarcerated until 2024.
Court ordered termination of parental rights to E.W. and S.W.; D.S.W. appealed challenging evidentiary rulings (a prison letter) and the best-interests analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory grounds support termination	County: conviction for listed sexual offense and egregious harm justify termination	D.S.W.: challenged admission of jailhouse letter and contested findings	Held: Conviction alone (criminal sexual conduct) is a sufficient statutory ground; evidentiary challenge is harmless
Whether district court abused discretion in best-interests finding	County: termination serves children's best interests given harm, denial, threats, incarceration, and adjustment	D.S.W.: court failed to articulate balancing and wrongly barred testimony about mother’s alleged insobriety	Held: No abuse of discretion; court’s findings adequately show consideration of best-interests factors
Admissibility/effect of prison/jailhouse letter	County: letter was admissible and relevant to credibility/relationship risk	D.S.W.: letter should have been excluded; its admission prejudiced outcome	Held: Court declined to resolve admissibility because the conviction ground made any error harmless
Relevance of mother’s alleged insobriety to best interests	D.S.W.: mother’s insobriety was relevant and should have been admitted	County: mother’s sobriety irrelevant to whether termination was in children’s best interests given risks from father	Held: Alleged insobriety was not material to the best-interests analysis; exclusion not reversible error

In re Welfare of Child of R.D.L., 853 N.W.2d 127 (Minn. 2014) (district court discretion in termination)
In re Welfare of Children of T.R., 750 N.W.2d 656 (Minn. 2008) (only one statutory ground needed for termination)
In re Welfare of Children of J.R.B., 805 N.W.2d 895 (Minn. App. 2011) (review standard for statutory-basis determination)
In re Welfare of R.T.B., 492 N.W.2d 1 (Minn. App. 1992) (best-interests balancing factors)
In re Tanghe, 672 N.W.2d 623 (Minn. App. 2003) (district court must consider best interests and explain rationale)