In re A.C.G.

Summary

The District of Columbia Court of Appeals affirmed an order terminating a biological mother's parental rights and granting adoption of the child to her paternal great-aunt. The court held that clear and convincing evidence supported termination under the statutory best-interests factors, including the child's longstanding continuity of care with the great-aunt and the mother's failure to address safety concerns arising from sexual abuse. The court also held that the great-aunt's advanced age did not make the adoption contrary to the child's best interests because backup caretakers and financial arrangements had been established.

Holdings

1. The evidence was sufficient to support termination of the mother's parental rights under the statutory best-interests factors, including the child's need for continuity and permanence, the parties' physical and emotional circumstances, and the quality of the child's relationships.
2. The trial court did not abuse its discretion in granting the adoption despite A.C.G.'s advanced age because age alone was not a bar, and A.C.G. had provided nearly continuous care, established backup caretaking arrangements, and made financial plans for the child's future.
3. Rejecting guardianship in favor of adoption was not an abuse of discretion because guardianship would have left the child in legal limbo and would not have provided the same permanency and stability.

Questions Presented

1. Whether sufficient evidence supported termination of the biological mother's parental rights under D.C. Code § 16-2353(b).
2. Whether the trial court abused its discretion by finding that adoption by the child's elderly paternal great-aunt was in the child's best interests.
3. Whether guardianship, rather than adoption, was an adequate alternative or would leave the child in legal limbo.

Disposition

affirmed