M.C. v. State, 318 P.3d 1195

Mother appeals a June 24, 2013 order terminating her parental rights.
The juvenile court found multiple grounds for termination and concluded termination was in the children's best interests.
The court relied on Mother’s history of violent behavior and domestic violence in the presence of the children.
Mother had not been offered reunification services, and there is a statutory presumption against entitlement due to prior parental-rights terminations.
The children are in foster care and thriving there, with a foster family seeking adoption and providing stability.
The court noted the children’ needs for a permanent, violence-free home and for permanency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence that Mother is an unfit parent?	Mother argues insufficient evidence of unfitness.	State asserts evidence supports unfitness due to violent history.	Yes; unfitness proven.
Was Mother entitled to reunification services and did lack of offering affect the outcome?	Mother claims entitlement to reunification services.	No constitutional right to services; presumption against due to prior terminations.	No error; services not required.
Did the evidence support the best interests finding to terminate parental rights?	Mother asserts best interests were not met by termination.	Court found continued violence and instability harmed children; foster placement is stable and adoptive.	Yes; best interests supported termination.

In re B.R., 2007 UT 82 (Utah Supreme Court (2007)) (clear weight of the evidence standard; deference to juvenile court credibility)
In re LM., 2001 UT App 314 (Utah App. 2001) (standard for reviewing factual findings; credibility assessed by court)
In re E.R., 2001 UT App 66 (Utah App. 2001) (clearly erroneous standard; deference to juvenile court findings)
In re N.R., 967 P.2d 951 (Utah Ct. App. 1998) (reunification services are gratuity; no constitutional right to them)
In re R.A.J., 1999 UT App 829 (Utah App. 1999) (ground-based termination suffices if best interests shown; appellate reweighing discouraged)