In the Term. of the Parent-Child Relationship of: E.S., Ed.B. and El.B. (Minor Children), and B.B. (Father) v. The Ind. Dept. of Child Services (mem. dec.), 71A03-1603-JT-684

DCS became involved in 2012 over domestic violence; CHINS adjudications followed for Ed.B. and El.B.
In 2013–2014, DCS reunification efforts continued with Father participating in services, including substance abuse treatment and therapy.
Father complied with services and demonstrated bonding with all three children; Mother’s noncompliance led to concerns about safety and supervision.
In 2014–2015, visits were supervised or intermittent; concerns remained about Father’s parenting boundaries and co-dependency with Mother.
In 2015–2016, DCS petitioned to terminate parental rights; the trial court issued findings concluding the reasons for removal would not be remedied and termination was in the children's best interests. The Court of Appeals reversed, finding insufficient grounds and inadequate findings to support termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court clearly erred in terminating parental rights	Father argues conditions leading to removal may have been remedied and risks were not proven.	DCS argues there is a reasonable probability conditions won't be remedied and continued risk supports termination.	Termination reversed; insufficient, non-specific findings

In re G.Y., 904 N.E.2d 1257 (Ind. 2009) (two-step analysis for remediation and best interests; clear and convincing burden)
K.E. v. Ind. Dep’t of Child Servs., 39 N.E.3d 641 (Ind. 2015) (termination requires substantial probability of adverse effects if parental duties continue)
In re V.A., 51 N.E.3d 1140 (Ind. 2016) (reaffirms need for adequate findings; certainty of decision paramount)
In re E.M., 4 N.E.3d 636 (Ind. 2014) (consideration of changed conditions and habitual patterns)
In re A.I., 825 N.E.2d 798 (Ind. Ct. App. 2005) (court may consider conditions resulting in continued placement outside home)