In the Interest of S. R. R., a Child (Mother)
The juvenile court entered an order ending the mother’s parental rights after finding her son deprived and concluding the deprivation was likely to persist and cause serious harm. The mother appealed the termination order but not the earlier deprivation finding, so the appellate court assumed the child’s deprivation was supported by the mother’s past lack of proper care or control. By the termination hearing, the mother had completed most case-plan goals, consistently visited and bonded with her son, maintained a clean and stable home, and begun working; the putative father had moved out months earlier. The court held the record did not establish with clear and convincing evidence that the mother was presently unfit or that deprivation was likely to continue and cause serious harm. Her disability, limited income, and past unfitness did not alone justify termination, and the record did not show that her prescribed medication or health conditions made her incapable of caring for her son. The court reversed the termination order.
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