Cited by

(holding that the parent’s failure to satisfy key elements of the case plan provides “ample evidence of his lack of compliance with the duties and responsibilities of the parent -child relationship”).

In re Child of Simon , (explaining that Minn. R. Evid.

(noting that the court may consider “the fact of incarceration in conjunction with other evidence supporting the petition for termination”).

Even if the district court erroneously admitted evidence, a new trial is warranted “only if the complaining party demonstrates prejudicial error.”

Mother relies on In re Child of Simon, where we stated that a parent’s “failure to satisfy key elements of the court-ordered case plan provides ample evidence of his lack of compliance with the duties and responsibilities of the parent-child relationship.”

re “(1) made by a person with personal knowledge of the matters recorded and a business duty to report accurately or from information transmitted by a person with such knowledge, (2) made at or near the time of the recorded event, (3) kept in the course of a regularly conducted business activity, and (4) made as part of the regular practice of that business activity.” In re Child of Simon , see Minn. R. Evid.

(determining that consideration of inadmissible hearsay was harmless error when “the record contain[ed] evidence” other than the hearsay evidence “that is independently sufficient to support the district court’s decision to terminate .

“A parent’s failure to satisfy key elements of the court-ordered case plan provides ample evidence of lack of compliance with the duties of the parent and child relationship.”

However, the district court may terminate parental rights only for “grave and weighty reasons.”

He is co rrect that “a parent’s incarceration alone is not enough to warrant termination of parental rights.” d 155, 162 (Minn. App. 2003).

(affirming a dist rict court’s decision to terminate parental rights when the parent did not show that an evidentiary error was prejudicial).

In re Child of Simon , (M inn.

In re Child of Simon , (citing Minn. R. Evid.

d 155, 160 (Minn. App. 2003).

And while a district court cannot terminate a parent’s rights solely based on incarceration, it “may consider the fact of incarceration in conjunction with other evidence suppo rting the petition for termination.”

See In re Child of Simon , (stating that failure to comply with key elements of court-ordered case plan provides ample evidence of neglect for duties of parent -child relationship).

While stating that a parent’s incarceration cannot be the sole basis for terminating parental rights, the district court properly considered appellant’s incarcerations in combination with other evidence supporting the TPR petition

-67 (Min n. App. 2012) (affirming a termination of parental rights based on failure to comply with parental duties, noting both that the parent failed to comply with the case plan and that the record ot herwise showed that the parent did not adequately care for the children); d 155, 163-64 (Minn. App. 2003) (describing a parent’s failure to comply with key case-plan components, the parent’s failure to provide meaningful parenting to the child, and the lack of evidence that the parent possessed t

also argues that this case is distinguishable from

1(b)(2), this case is not analogous to

See, e.g., K.S.F., d at 666-67 (affirming a termination of parental rights based on failure to comply with parental duties, noting both that the parent failed to comply with the case plan and that the record otherwise showed that the parent did not adequately care for the children); (describing a parent’s failure to comply with key case-plan components, the parent’s failure to provide meaningful parenting to the child, and the lack of evidence that the parent possessed the skills and knowledge t

“Parental rights may be terminated only for grave and weighty reasons.”

rights if it finds “that the parent has substantially, continuously, or repeatedly refused or neglected to comply with the duties imposed upon that parent by the parent and child relationship.” Failure to satisfy key elements of the court-ordered case plan “provides ample evidence” of noncompliance “with the duties and responsibilities of the parent-child relationship.” (quotation omitted).

Failure to satisfy key elements of a court-ordered case plan can provide “ample evidence of [a] lack of compliance with the duties and responsibilities of the parent-child relationship.”

I. Father argues that the district court “erred in terminating [his] parental rights for failing to comply with voluntary case-planning services.” (stating, in the context of a termination under Minn. Stat. § 260C.301, subd.