In the Termination of the Parent-Child Relationship of: C.H. (Minor Child), and D.S. (Father) v. The Indiana Department of Child Services (mem. dec.), 21A01-1609-JT-2108

Father (D.S.) was incarcerated for dealing heroin around the time C.H. was born in January 2015; the newborn tested positive for opiates and methadone.
DCS filed a CHINS petition in February 2015; Father admitted C.H. was a CHINS at the initial hearing.
Father had never met C.H.; his earliest release date from prison was April 20, 2017, and he remained incarcerated at the August 2016 termination hearing.
Father completed some parenting classes in custody but indicated he did not want further services and told the case manager he was "just done" when told the plan would change to adoption.
DCS and the CASA recommended termination based on C.H.’s need for permanency and Father’s inability to provide stable housing, supervision, or income.
The trial court terminated Father’s parental rights; Father appealed only the best-interests prong of the statutory termination standard.

Issue	Plaintiff's Argument (DCS)	Defendant's Argument (Father)	Held
Whether termination was in the child’s best interests	Termination is necessary for the child’s permanency given Father’s lifelong incarceration during C.H.’s life, lack of relationship, instability, and refusal of services	Insufficient evidence that termination is in C.H.’s best interests; relies on R.S. to argue closeness/visitation factors should weigh against termination	Court affirmed: clear-and-convincing evidence supports best interests finding and termination because Father never formed a relationship, was incarcerated since birth, and could not guarantee housing or custody upon release

In re K.T.K., 989 N.E.2d 1225 (Ind. 2013) (standard of review and burden of proof in parental termination cases)
In re Bester, 839 N.E.2d 143 (Ind. 2005) (parental rights may be terminated when parents cannot meet responsibilities)
In re L.S., 717 N.E.2d 204 (Ind. Ct. App. 1999) (termination aims to protect child, not punish parent)
In re the Involuntary Termination of the Parent-Child Relationship of R.S., 56 N.E.3d 625 (Ind. 2016) (reversal where strong parent–child bond and ongoing visitation supported denial of termination)
Castro v. State Office of Family and Children, 842 N.E.2d 367 (Ind. Ct. App. 2006) (upholding termination where father was incarcerated his child’s entire life and could not provide housing or stability)
Matter of A.C.B., 598 N.E.2d 570 (Ind. Ct. App. 1992) (criminal activity can impede development of parent–child relationships)