Termination: C.T. v. Indiana Department of Child Services (mem. dec.), 32A05-1610-JT-2398

A.S., born prematurely with significant medical and developmental needs, spent the first ~10 weeks of life hospitalized and requires ongoing speech, physical, and occupational therapy.
DCS removed A.S. after parents visited infrequently in the hospital and because of parental instability (housing/employment); A.S. was placed with maternal grandmother.
Father was adjudicated in CHINS, ordered to complete services (parenting assessment, mental-health treatment, stable housing/employment, consistent visits, Fatherhood Engagement Services).
Father inconsistently engaged: completed only an initial mental-health assessment, began Fatherhood Engagement Services a year late, had sporadic supervised visitation, and had frequent moves and short-term jobs.
DCS petitioned to terminate parental rights; the Family Case Manager and Guardian ad Litem recommended termination based on Father’s lack of stability and insufficient bond/engagement with A.S.
Trial court terminated Father’s rights concluding conditions leading to removal were unlikely to be remedied and termination was in child’s best interests; Father appealed arguing insufficient evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supports finding a reasonable probability conditions causing removal will not be remedied	DCS: Father’s unstable housing, employment, inconsistent visitation, and failure to comply with services show conditions unlikely to be remedied	Father: He improved (employment, resumed visitation, engaged in Fatherhood program) and thus conditions can be remedied	Court held evidence clearly and convincingly supports that conditions are unlikely to be remedied (affirmed)
Whether continuation of parent-child relationship posed a threat to child’s well-being	DCS: child’s special needs require stable caregiver and Father’s instability threatens welfare	Father: improved engagement undermines threat claim	Court did not decide this ground because proving one statutory ground sufficed (remedial probability ground upheld)
Whether termination is in child’s best interests	DCS/GAL: A.S. needs stable home and consistent caregiver to manage therapies and developmental needs	Father: continued relationship and recent improvements favor preservation of rights	Court held termination was in A.S.’s best interests given need for stability and Father’s history of instability
Whether plan for child’s care was satisfactory	DCS: Adoption plan with maternal grandmother (placement) is satisfactory	Father: challenged some findings but did not contest plan adequacy	Court found DCS’s adoption plan satisfactory

In re K.T.K., 989 N.E.2d 1225 (Ind. 2013) (standard of review and burden for termination of parental rights)
In re V.A., 51 N.E.3d 1140 (Ind. 2016) (review whether findings are clearly and convincingly supported)
In re K.E., 39 N.E.3d 641 (Ind. 2015) (parent’s changed conditions weighed against habitual conduct; services and response are relevant)
R.J. v. Ind. Dep’t. of Child Servs., 56 N.E.3d 729 (Ind. Ct. App. 2016) (statutory disjunctive interpretation of termination grounds)
Kitchell v. Franklin, 26 N.E.3d 1050 (Ind. Ct. App. 2015) (unchallenged findings can support judgment)