S.Z.O. v. Harrison County Department of Child Protection Services, by Marcus D. Davenport, and M.A.B., A Minor, By and Through Her Next Friend, Marcus D. Davenport, 396 So.3d 1225

S.Z.O. is the biological mother of M.A.B., who was taken into Harrison County Child Protection Services (CPS) custody in January 2021 at four months old after testing positive for cocaine.
S.Z.O. knew or should have known that her child was living in a home where multiple adults used drugs; she also tested positive for cocaine just after the child's removal from her custody.
CPS and the Youth Court developed and ordered compliance with a reunification service plan, including requirements for stable housing, employment, parenting classes, drug treatment, and visitation; S.Z.O. repeatedly failed to fully comply.
Over two years, S.Z.O. had intermittent employment, unstable housing, no consistent transportation, and failed out of family intervention and parenting programs. She also did not maintain consistent visitation with M.A.B.
By April 2023, M.A.B. had lived with foster parents for more than two years. GAL and CPS professionals testified the child had bonded with her foster family, and that termination of parental rights was in the child's best interests.
The Youth Court terminated S.Z.O.’s parental rights based on clear and convincing evidence of unfitness, substantial non-compliance with reunification efforts, and that termination was in M.A.B.’s best interests. The Mississippi Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clear and convincing evidence supported TPR	S.Z.O. substantially complied, had employment & housing	CPS: S.Z.O.’s failures showed unfitness and non-compliance	Yes; evidence supported unfitness and non-compliance
Whether S.Z.O.’s efforts were sufficiently reasonable	S.Z.O. pointed to clean drug screens, some effort at programs	CPS: Frequent missed obligations, positive drug tests	Efforts insufficient for reunification
Whether termination was in M.A.B.’s best interests	S.Z.O. could provide for M.A.B.; wanted reunification	CPS: Child’s bond with foster parents, parent’s instability	Termination was in best interests of M.A.B.
Whether less restrictive alternatives could be met	S.Z.O. had recently stabilized finances, could resume custody	CPS: Instability persisted, relationship with M.A.B. eroded	No viable alternative existed to termination

S.F. v. Lamar Cnty. Dep’t of Child Prot. Servs., 373 So. 3d 985 (Miss. 2023) (establishes standard of review for findings of fact in youth court TPR cases)
R.B. v. Winston Cnty. Dep’t of Child Prot. Servs., 291 So. 3d 1116 (Miss. Ct. App. 2019) (only one statutory ground is needed to justify termination of parental rights)
Bullock v. Miss. Dep’t of Child Prot. Servs., 343 So. 3d 1079 (Miss. Ct. App. 2022) (failure to appeal prior youth court orders bars challenge to those findings on appeal)
In re B.A.H., 225 So. 3d 1220 (Miss. Ct. App. 2016) (substantial erosion of parent-child relationship supports TPR)