S.R., MOTHER OF E.C. AND S.R., MINOR CHILDREN
v.
DEPARTMENT OF CHILDREN AND FAMILIES
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A mother appeals a final judgment terminating her parental rights under Florida law for failing to substantially comply with her case plan. Although the mother demonstrated recent progress, the appellate court affirmed the termination, holding that competent, substantial evidence supported the trial court's findings that statutory grounds existed, termination was in the children's best interests, and it was the least restrictive means of protecting them.
The appellate court affirmed the termination, holding that competent, substantial evidence supported: (1) the existence of a statutory ground for termination under section 39.806(1)(e)1; (2) the trial court's finding that termination is in the children's manifest best interests; and (3) that termination is the least restrictive means of protecting the children from harm.
[1] Termination of parental rights may be affirmed when competent, substantial evidence supports the trial court's determination that a statutory ground for termination exist…
[2] A parent's recent progress does not preclude termination of parental rights if competent, substantial evidence supports the trial court's findings.
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Join FLexlaw to unlock all legal intelligence“competent, substantial evidence supports the trial court's determination that a statutory ground for termination of parental rights exists, that termination is in the children's manifest best interests, and that termination is the least restrictive means of protecting the children from harm”
Establishes the three-part test for upholding termination of parental rights on appeal
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Join FLexlaw to unlock all legal intelligenceThe case involved minor children E.C. and S.R. whose mother was found to have failed to substantially comply with her case plan. Despite showing a slo…
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PER CURIAM.
The mother of minor children E.C. and S.R. appeals the final judgment terminating her parental rights under section 39.806(1)(e)1., Florida Statutes (2020), for failing to substantially comply with her case plan. Despite her slow start, the testimony at trial showed that the mother has made recent progress. Even so, competent, substantial evidence supports the trial court’s determination that a statutory ground for termination of parental rights exists, that termination is in the children’s manifest best interests, and that termination is the least restrictive means of protecting the children from harm. See J.B. v. C.S., 186 So. 3d 1142, 1143 (Fla. 1st DCA 2016) (affirming termination despite
evidence of the parent’s “marked improvement”); N.L. v. Dep’t of Children & Families, 843 So. 2d, 996, 1000 (Fla. 1st DCA 2003) (“Where the trial court’s findings that the evidence is clear and convincing are supported by competent substantial evidence, and the appellate court cannot say that no one could reasonably find such evidence to be clear and convincing, the finding will not be set aside on appellate review.”). AFFIRMED.
KELSEY, NORDBY, and LONG, JJ., concur. _____________________________