In the Matter of the Termination of the Parent-Child Relationship of J.R.J., Sr., Father, and Ja.R.J., Je.R.J. and Ju.J., Minor Children, J.R.J., Sr. v. Indiana Department of Child Services (mem. dec), 40A04-1706-JT-1276

Father (J.R.J., Sr.) provided methamphetamine to his then-wife (Stepmother) in 2014; she ingested it, was hospitalized, and died; DCS removed the three children thereafter and Father was arrested and jailed on federal drug charges.
Father remained incarcerated throughout CHINS and termination proceedings and was later convicted and sentenced to concurrent life terms.
Children were first placed with maternal aunt, then in foster care where they remained for over two years; they suffered chronic trauma and various mental-health diagnoses (ADHD, ODD, RAD, anxiety/PTSD).
DCS changed the permanency plan to termination of parental rights in June 2015 and filed the termination petition against Father in February 2016.
Evidence at the consolidated termination/guardianship hearing included caseworker, therapist, and guardian ad litem testimony that the children had improved in foster care, needed ongoing services, and preferred permanency away from the neighborhood where the trauma occurred.
Juvenile court found (among other things) a reasonable probability the removal conditions would not be remedied, continuation of the parent-child relationship threatened the children’s wellbeing, termination was in the children’s best interests, and adoption was a satisfactory plan; court terminated Father’s parental rights and the Court of Appeals affirmed.

Issue	Father's Argument	DCS/Respondent's Argument	Held
Whether termination was clearly erroneous	Father argued DCS failed to prove by clear and convincing evidence that (1) conditions leading to removal would not be remedied; (2) continuation of the relationship posed a threat; (3) termination was in children's best interests; and (4) DCS had a satisfactory plan	DCS argued evidence of Father’s criminal conduct, incarceration, children’s trauma, therapeutic progress in foster home, and plan to pursue adoption met statutory elements by clear and convincing evidence	Affirmed: court held findings supported that at least one statutory ground (reasonable probability conditions would not be remedied) and best-interest/satisfactory-plan elements were met

E.M. v. Ind. Dep’t of Child Servs., 4 N.E.3d 636 (Ind. 2014) (high deference to trial courts in termination cases; fitness judged at time of proceedings)
K.T.K. v. Ind. Dep’t of Child Servs., 989 N.E.2d 1225 (Ind. 2013) (two-step test to assess whether removal conditions will be remedied)
Bester v. Lake Cnty. Office of Family & Children, 839 N.E.2d 143 (Ind. 2005) (parental rights are constitutional but may be terminated when parent cannot meet responsibilities)
In re H.L., 915 N.E.2d 145 (Ind. Ct. App. 2009) (appellate standard: do not reweigh evidence or judge credibility; affirm unless clearly erroneous)
In re A.S., 17 N.E.3d 994 (Ind. Ct. App. 2014) (testimony of service providers and case manager recommendations can support best-interest finding)
Lang v. Starke Cnty. Office of Family & Children, 861 N.E.2d 366 (Ind. Ct. App. 2007) (satisfactory permanency plan need not be detailed; plan to seek adoption is sufficient)
Castro v. State Office of Family & Children, 842 N.E.2d 367 (Ind. Ct. App. 2006) (courts need not wait for irreversible harm before terminating rights; children’s need for permanency is important)
A.F. v. Marion Cnty. Office of Family & Children, 762 N.E.2d 1244 (Ind. Ct. App. 2002) (courts may consider criminal history, substance abuse, and lack of housing/employment in remediation analysis)