Cited by

For the business-records exception to apply, “a qualified witness must testify that the records were kept in the course of a regularly -conducted business activity, and that it was the normal practice of that business to keep such records.”

“Because the be st-interests analysis involves credibility determinations and is generally not susceptible to an appellate court’s global review of a record, we give considerable deferenc e to the district court’s findings.” (quotation omitted).

While there is no statutory definition of “good cause” for purposes of a voluntary termination of parental rights, a factual basis for good cause “center[s] on the child’s best interests.” (noting that “ good cause for voluntary termination [of parental rights] exists under a variety of circumstances usually related to the best interests of the child”), review denied (Minn. Sept.

d 76, 87 (Minn. App. 2012) (citations and quotation omitted).

“We review an order terminating parental rights to determine whether the district court’s findings (1) address the statutory cr iteria and (2) are supported by substantial evidence.”

Ultimately, however, [appellate courts] review the factua l findings for clear error and the statutory basis for abuse of discretion.” (citations and quotation omitted).

T.R., d at 661; see also A.J.C., d at 622 (stating that evidence must relate to conditions in existence at the time of hearing).

However, “[r]easonable efforts encompass more than just a case plan” and the required services “must be aimed at alleviating the conditions that gave rise to out-of-home placement.”

6 J.K.T., (“The county’s efforts must be aimed at alleviating the conditions that gave rise to out-of-home placement, and they must conform to the problems presented.”).

(citations and quotations omitted); -61 (Minn. 2008); d at 385; In re Welfa

D E C I S I O N I. Standard of review District courts may terminate parental rights only “for grave and weighty reasons.” (quotation omitted).

However, “[r]easonable efforts encompass more than just a case plan” and the required services “must be aimed at alleviating the conditions that gave rise to out-of -home placement.”

(“A parent’s substantial compliance with a case plan may not be enough to avoid termination of parental rights when the record contains clear and convincing evidence supporting termination.”).

The efforts must be aimed at correcting the conditions which led to out-of-home placement and “must conform to the problems presented.”

“A district court abuses its discretion if it improperly applies the law.” review denied (Minn. July 17, 2012).

The county’s 8 efforts must “be aimed at alleviating the c onditions that ga ve rise to out -of-home placement, and they must conform to the pr oblems presented.”

(stating that reasonable efforts must be aimed at correcting conditions which led to out-of- home placement).

D E C I S I O N An appellate court reviews an order that terminates parental r ights “to determine whether the district court’s findings (1) address the statutory criteria and (2) are supported 7 by substantial evidence.”

“A district court abuses its discretion if it improperly applies the law.” d 76, 93 (Minn. App. 2012).

“Because the best-interests analysis involves credibility determinations and is generally not susceptible to an appellate court’s global review of a record, we give considerable deference to the district court’s findings.” d 76, 92 (Minn. App. 2012) (quotation omitted).

A finding of fact is clearly erroneous if it is “manifestly contrary to the weight of the evidence or not reasonably supported by the evidence as a whole.” (quoting In re Children of T.R.

d 76, 87 (Minn. App. 2012).

“A district court 12 abuses its discretion if it improperly applies the law.”

D E C I S I O N An appellate court reviews an order that terminates parental rights “to determine whether the district court’s findings (1) address the statutory criteria and (2) are supported by substantial evidence.”

(citing Dobrin v. Dobrin , ).

d 315, 323 (Minn. App. 2015), review denied (Minn. July 20, 2015)

“A district court abuses its discretion if it improperly applies the law.” d 76, 93 (Minn. App. 2012).

93 (Minn. App. 2012) A. Mother does not challenge the district court's findings of statutory grounds to terminate her parental rights.

“A district court abuses its discretion if it improperly applies the law.” A. Mother does not challenge the district court’s findings of s tatutory grounds to terminate her parental rights.

(noting that in termination for failure to correct conditions, “[t]he critical issue is .