In re H.J.

Summary

The New Hampshire Supreme Court affirmed the termination of a father's parental rights based on abandonment and inadequate support. The court held that the father failed to rebut the statutory presumption of abandonment, and that termination was in the child's best interest given the father's minimal contact, repeated incarcerations, and lack of meaningful efforts to establish a relationship with the child.

Holdings

1. The father abandoned H.J. because his contacts and support were minimal and not substantial, and his conduct demonstrated a failure to assume responsibility for the child's care and well-being.
2. Termination of the father's parental rights was in H.J.'s best interest.
3. The court did not need to decide the father's challenge to the non-support finding because RSA 170-C:5 permits termination when one or more statutory grounds are established, and the abandonment finding independently supported termination.

Questions Presented

1. Whether the evidence established beyond a reasonable doubt that the father abandoned H.J. under RSA 170-C:5, I.
2. Whether the father's periods of incarceration, the domestic-violence order, and the mother's denial of a 2011 visit precluded a finding of abandonment or required greater consideration of his contacts with the child.
3. Whether termination of the father's parental rights was in H.J.'s best interest.
4. Whether the alleged failure to provide adequate support required reversal despite the separate finding of abandonment.

Disposition

affirmed