Juvenile court properly declined to apply a parent-child exception to adoption because the bond between mother and child was insufficient. Parents appealed the termination of parental rights, arguing that the juvenile court erred by failing to apply the parent-child relationship exception to adoption. The appellate court rejected the argument and affirmed. The evidence supported a determination that mother did maintain regular visitation and contact with the minor and had a “healthy” bond with him. However, the minor had been removed when he was one month old, and mother never progressed beyond monitored visitation. While visits between mother and the minor may have been pleasant, there was no evidence that termination of the parent-child relationship would be detrimental to the minor or that the relationship conferred benefits to the minor more significant than the permanency and stability offered by adoption.
Case Summaries