Term. of Parent-Child Rel. of D.K. O.K. v. Indiana Department of Child Services, 968 N.E.2d 792

D.K. (born Oct 2008) was removed from Mother O.K. in 2009 due to neglect and placed in foster care.
D.K. was adjudicated a CHINS on Apr 7, 2009; Mother was required to complete parenting classes, obtain stable housing, and maintain employment.
Mother moved between at least eight residences over two years and failed to complete required programs or GED.
Mother was placed in a group home with D.K. but violated rules (alcohol possession, boyfriends staying overnight) and D.K. was returned to foster care.
DCS offered to arrange interstate placement to reunify, but Mother declined; she did not engage with service providers or counseling after initial referral.
TPR petition filed Mar 23, 2011; after hearings, the trial court terminated Mother’s parental rights on Sep 20, 2011; foster parents want to adopt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clear and convincing evidence supports termination	O.K. contends conditions would be remedied by reunification efforts.	DCS argues conditions unlikely to be remedied given prolonged instability and non-compliance.	Yes; conditions unlikely to be remedied; termination affirmed.

In re I.A., 934 N.E.2d 1127 (Ind. Ct. App. 2010) (two-tier review; deference to trial court credibility)
In re J.T., 742 N.E.2d 509 (Ind. Ct. App. 2001) (reasonable probability standard for remedying conditions)
In re A.I., 825 N.E.2d 798 (Ind. Ct. App. 2005) (consideration of continued placement beyond initial removal)
McBride v. Monroe County Office of Family and Children, 798 N.E.2d 185 (Ind. Ct. App. 2003) (parental duties and patterns; consideration of services offered)
Graham v. State, 941 N.E.2d 1091 (Ind. Ct. App. 2011) (judicial notice; records and appellate record completeness)