In re J.G.

Summary

The Montana Supreme Court reviewed the termination of R.G.'s parental rights to her three children. The court held that the District Court properly considered parenting deficits and psychological abuse in addition to physical neglect, and that clear and convincing evidence supported findings that R.G. failed to comply with her treatment plan and was unlikely to change within a reasonable time. The court affirmed the termination as serving the children's best interests.

Holdings

1. The District Court properly considered R.G.'s parenting deficits and the resulting psychological abuse, as well as physical neglect, because the adjudication order and treatment plan placed R.G. on notice that those issues would be considered and the termination petition alleged failure to comply with the treatment plan.
2. The District Court did not clearly err in finding that the conditions rendering R.G. unfit were unlikely to change within a reasonable time.
3. The District Court did not clearly err in determining that termination of R.G.'s parental rights was in the children's best interests.

Questions Presented

1. Whether the District Court erred by considering parenting deficits and psychological abuse, in addition to physical neglect, when determining that R.G. failed to comply with the treatment plan.
2. Whether the District Court clearly erred in finding that R.G.'s condition was unlikely to change within a reasonable time.
3. Whether the District Court clearly erred in finding that termination of R.G.'s parental rights was in the children's best interests.

Disposition

affirmed