In re Interest of Q.A.H.

In 2012, the trial court terminated Mother’s parental rights over Child, determining that Mother, who had been under psychiatric care for three years before the termination hearing, had abused or neglected Child in that she had a mental condition that rendered her unable to provide Child the necessary care, custody and control and that she failed to provide adequate food, clothing, shelter or education to Child even though she had the financial resources to do so. The Supreme Court affirmed, holding (1) the trial court did not err in discrediting testimony from Mother’s psychiatrist and therapist regarding her mental condition at the time of the termination hearing or in finding Mother’s custody of another child did not show Mother could provide the necessary care, control or custody to Child; (2) substantial evidence supported the trial court’s finding that Mother’s personal relationships presented a potential harm for Child despite Mother’s therapy; and (3) the trial court did not err in finding that Mother’s de minimus financial support to Child did not show that she provided adequate support to Child before the termination hearing. View "In re Interest of Q.A.H." on Justia Law