In the Matter of the Welfare of the Child of: M.C., Parent

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-0716

In the Matter of the Welfare of the Child of: M.C., Parent.

Filed November 17, 2025
Affirmed
Cochran, Judge

Hennepin County District Court
File No. 27-JV-24-2721

Anne Morris Carlson, Anne M. Carlson Law Office, PLLC, St. Paul, Minnesota (for
appellant M.C.)

Mary F. Moriarty, Hennepin County Attorney, Britta Nicholson, Assistant County
Attorney, Minneapolis, Minnesota (for respondent Hennepin County Human Services and
Public Health Department)

Maureen Menikheim, Minneapolis, Minnesota (guardian ad litem)

Considered and decided by Bjorkman, Presiding Judge; Cochran, Judge; and Cleary,

Judge. 1

NONPRECEDENTIAL OPINION

COCHRAN, Judge

On appeal from the termination of her parental rights, appellant-mother challenges

the district court’s determinations that respondent-county made reasonable efforts to

1
Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.
reunite her with the child, that termination is supported by a statutory basis, and that

termination is in the best interests of the child. We affirm.

FACTS

This case concerns the termination of appellant-mother M.C.’s parental rights to her

child, F.R.C., born in 2021. 1 The following summarizes the district court’s findings of fact

in its order terminating parental rights as well as the procedural history, and is

supplemented by the record, as necessary, to understand the issues on appeal.

In February 2021, following the child’s birth, respondent Hennepin County Human

Services and Public Health Department (the county) received a report that the child may

have had prenatal exposure to drugs and that mother had a prior termination of parental

rights to another child. In October 2021, the county filed a petition to open a child-in-need-

of-protection-or-services (CHIPS) case for the child. The district court adjudicated the

child CHIPS in January 2022, and the child was removed from mother’s home and placed

with relatives. The county filed a petition for termination of parental rights (TPR) in

October 2022. Following a three-day trial, the district court involuntarily terminated

mother’s parental rights in June 2023.

Mother appealed the district court’s decision. See In re Welfare of Child of M.A.C.,

No. A23-1149, 2024 WL 323335, at *1 (Minn. App. Jan. 29, 2024). We reversed the order

terminating mother’s parental rights and remanded based on our conclusion that the district

court clearly erred when it found that the county made reasonable efforts to reunify the

1
F.R.C.’s father is not involved in this appeal. Mother also has other children, who are not
part of the petition to terminate parental rights generating this appeal.

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family. Id. at *5. Our conclusion was focused on the lack of effort by the county to provide

mother with a chemical-health assessment as required by her case plan. Id. at *4-5. Our

opinion instructed “the district court to supervise [the] child’s juvenile-protection matter,

including the county’s provision of reasonable efforts to reunite the family.” Id. at *5. We

also stated, “Nothing in this opinion shall be construed as an expression of our opinion on

how the district court should resolve any future requests for relief.” Id.

Following remand, the district court dismissed the county’s 2022 TPR petition and

the matter reverted to a CHIPS proceeding. The county was ordered to provide mother

with an updated case plan and undertake reasonable efforts toward reunification. County

social worker P.B. discussed a proposed case plan with mother in February 2024. The case

plan required mother to: complete a chemical-health assessment and follow

recommendations; abstain from mood-altering substances; demonstrate ongoing sobriety

through random urinalysis (UA) testing; submit a baseline UA; complete a psychological

evaluation and follow recommendations; participate in parenting education until she is able

to demonstrate an ability to consistently meet the child’s needs as identified by the child’s

providers; comply with recommendations from the child’s services providers; maintain

safe and stable housing; provide information about household membership to the county

and allow the county to access the home; maintain contact with the county; remain law

abiding; comply with probation and all criminal court orders, as applicable; and participate

in visits with the child, as recommended by the child’s therapist. The county submitted the

proposed case plan to the district court in the spring of 2024.

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 Over the next several months, the county undertook efforts to provide services to

mother and coordinate with mother on her case plan. During this time period, the district

court denied mother’s requests for visitation. The district court determined that visitation

would not be in the child’s best interests until mother demonstrated her sobriety (which she

failed to do) and the child’s therapist approved visitation (which did not occur).

In September 2024, after approximately seven months of working with mother on

her case plan, the county filed a petition to terminate mother’s parental rights to the child.

The petition alleged that four statutory grounds for termination were met: (1) failure to

comply with the duties imposed by the parent-child relationship; (2) palpable unfitness;

(3) failure to correct the conditions that led to the child’s out-of-home placement, despite

reasonable efforts by the county; and (4) neglect of the child in foster care. See Minn. Stat.

§ 260C.301, subd. 1(b)(2), (3), (4), (7) (2024). The petition further asserted that the county

put forth reasonable efforts to rehabilitate mother and reunify mother with the child and

that termination was in the child’s best interests.

The district court held a six-day trial at which the following witnesses

testified: social workers F.L., A.R., M.M., K.S., and P.B.; a drug-testing director; a

parenting educator; foster mother; mother; and the guardian ad litem (GAL). The district

court also received into evidence over 100 exhibits.

In April 2025, the district court filed a written order terminating mother’s parental

rights to the child. Based on the testimony from the county’s witnesses, which the district

court found credible and persuasive, the district court concluded that the county proved by

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clear and convincing evidence that the four statutory grounds for termination alleged in the

petition were met.

The district court also concluded that the county made reasonable efforts to

rehabilitate mother and reunify mother with the child, as required by statute. In making

this determination, the district court credited testimony from the social workers regarding

the specific efforts the county made to assist mother with the case plan and reunite the

family. These efforts included, among others, regular outreach efforts to mother, referrals

for a chemical-dependency evaluation and a psychological evaluation, a referral to a

parenting-skills educator, referral to a peer-support program, measures to ensure that

mother abstained from mood-altering substances through the use of UA testing and sweat

patches, and meetings with mother to discuss case plan components. The district court also

determined the termination was in the child’s best interests. Consequently, the district

court ordered the termination of mother’s parental rights to the child.

Mother appeals.

DECISION

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

Welfare of M.D.O., 462 N.W.2d 370, 375 (Minn. 1990). To involuntarily terminate

parental rights, a district court must determine that (1) the county has made reasonable

efforts to rehabilitate the parent and reunify the family or such efforts were not required;

(2) at least one of the statutory grounds for terminating parental rights exists; and

(3) termination is in the child’s best interests. Minn. Stat. §§ 260C.301, subds. 1(b), 7, 8

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(2024); .317, subd. 1 (2024); see also In re Welfare of Child. of S.E.P., 744 N.W.2d 381,

385 (Minn. 2008).

We review a district court’s decision to terminate parental rights “to determine

whether the district court’s findings address the statutory criteria and whether the district

court’s findings are supported by substantial evidence and are not clearly erroneous.”

S.E.P., 744 N.W.2d at 385. “A finding is clearly erroneous if it is either manifestly contrary

to the weight of the evidence or not reasonably supported by the evidence as a whole.” In

re Welfare of Child. of T.R., 750 N.W.2d 656, 660-61 (Minn. 2008) (quotation omitted).

In reviewing the district court’s factual findings, “we view the evidence in a light favorable

to the findings.” In re Civ. Commitment of Kenney, 963 N.W.2d 214, 221 (Minn. 2021)

(addressing the clear-error standard of review); see also In re Welfare of Child of J.H.,

968 N.W.2d 593, 601 n.6 (Minn. App. 2021) (applying Kenney in a termination-of-

parental-rights appeal), rev. denied (Minn. Dec. 6, 2021). But, in reviewing the district

court’s ultimate decision to terminate parental rights, “[w]e give considerable deference to

the district court.” S.E.P., 744 N.W.2d at 385; see also J.H., 968 N.W.2d at 600 (stating

that we review district court’s ultimate decision to terminate parental rights for an abuse of

discretion). “We will affirm a termination order if at least one statutory ground for

termination is supported by clear and convincing evidence and termination is in the best

interests of the child, so long as the [county] made reasonable efforts to reunite the family

if reasonable efforts were required.” In re Welfare of Child of F.F.N.M., 999 N.W.2d 525,

534 (Minn. App. 2023), rev. denied (Minn. Jan. 5, 2024).

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 Mother challenges the district court’s determination on each of the statutory criteria

for involuntary termination of parental rights: reasonable efforts by the county, the

existence of at least one statutory ground for termination, and the child’s best interests. We

address her arguments on each criterion in turn.

I. The district court did not abuse its discretion in determining that the county
made reasonable efforts to rehabilitate mother and reunify mother with the
child.

Before terminating parental rights, a district court must specifically find that the

county has made reasonable efforts to rehabilitate the parent and reunify the family or find

that reasonable efforts are not statutorily required. Minn. Stat. § 260C.301, subd. 8; see

also Minn. Stat. § 260.012(a) (2024); T.R., 750 N.W.2d at 664. Reasonable efforts are

“services that go beyond mere matters of form so as to include real, genuine assistance.”

In re Welfare of Child. of S.W., 727 N.W.2d 144, 150 (Minn. App. 2007) (quotation

omitted), rev. denied (Minn. Mar. 28, 2007). The efforts “must be aimed at alleviating the

conditions that gave rise to out-of-home placement, and they must conform to the problems

presented.” In re Welfare of Child of J.K.T., 814 N.W.2d 76, 88 (Minn. App. 2012).

In determining whether a county’s efforts were reasonable, the district court must

consider whether the services offered were:

(1) selected in collaboration with the child’s family and, if
appropriate, the child;

(2) tailored to the individualized needs of the child and child’s
family;

(3) relevant to the safety, protection, and well-being of the
child;

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 (4) adequate to meet the individualized needs of the child and
family;

(5) culturally appropriate;

(6) available and accessible;

(7) consistent and timely; and

(8) realistic under the circumstances.

Minn. Stat. § 260.012(h) (2024). The district court also weighs “the length of the time the

county was involved and the quality of effort given.” In re Welfare of H.K., 455 N.W.2d

529, 532 (Minn. App. 1990), rev. denied (Minn. July 6, 1990). “[W]hat constitutes

‘reasonable efforts’ depends on the facts of each case.” J.H., 968 N.W.2d at 601 We

review the district court’s determination about the reasonableness of the county’s efforts

for an abuse of discretion and the related findings of fact for clear error. In re Welfare of

Child of D.L.D., 865 N.W.2d 315, 322-23 (Minn. App. 2015), rev. denied (Minn. July 20,

2015).

Here, the district court found that the county made reasonable efforts “that afforded

[mother] with a meaningful opportunity” to correct the conditions that led to the child’s

out-of-home placement (chemical dependency and mental-health needs) and promote

reunification with the child. The district court noted that many of the county’s services

were offered to mother when the first CHIPS proceeding began in 2021, and that the county

maintained these services “despite lack of contact with [mother] and [mother’s] failure to

engage in services.” The district court specifically found that the county provided the

following services to mother after remand: (1) referrals for a chemical-dependency

evaluation and offers to assist with scheduling, attendance, and transportation to

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appointments; (2) referrals for UAs and sweat patch testing to demonstrate sobriety;

(3) referrals for an updated psychological evaluation; (4) referrals for parenting-education

services; (5) peer-support programming; (6) housing support; (7) outreach attempts to

mother and meetings to discuss the case plan and mother’s needs; (8) ongoing monitoring;

(9) attempts to connect mother with the child’s services providers; (10) monthly financial

assistance for phone and transportation; and (11) provision of a cell phone to maintain

contact with ongoing social workers and contact resources. The district court also found

that

[t]hese services have been selected in collaboration with the
family to the degree possible, tailored to the individualized
needs of the family, are relevant to the safety, protection and
well-being of the child, adequate to meet the needs of the child
and family, culturally appropriate, available and accessible,
consistent and timely, and realistic under the circumstances.

(Emphasis added.)

Mother presents three arguments challenging the district court’s determination that

the county made reasonable efforts toward rehabilitation and reunification. We address

each argument below. We conclude that the district court did not clearly err in its factual

findings regarding the services made available to mother and we further conclude that the

district court did not abuse its discretion when it determined that the county’s efforts to

rehabilitate mother and reunify the family were reasonable.

Collaboration with the Family

Mother first challenges the district court’s finding that the services provided by the

county were “selected in collaboration with the family to the degree possible.” Mother

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argues that this finding was clearly erroneous because the services were not selected in

collaboration with the family. The county responds that the district court’s finding is not

clearly erroneous because the record reflects that the county tried to collaborate with

mother, but she refused to provide input and denied that she had any need for services. The

county also argues that mother’s lack of communication does not equate to a failure to

provide services in collaboration with the family. We agree with the county.

In a proceeding to terminate parental rights, the district court must make findings as

to whether the county made reasonable efforts including consideration of whether the

services provided by the county were “selected in collaboration with the child’s family and,

if appropriate, the child.” Minn. Stat. § 260.012(h)(1). As noted above, the district court

considered this factor and found that the county offered a number of services to mother and

the child that were “selected in collaboration with the family to the degree possible.”

(Emphasis added.)

The record supports the district court’s finding. For example, social worker P.B.

testified that she called mother in February 2024, following remand, to talk about what

services mother would need and her case plan. Mother responded by telling the social

worker P.B. that she was not going to participate in her case plan and that she had no need

for services. Social worker P.B. also testified that mother was difficult to reach. Likewise,

other social workers who worked with mother after P.B. testified that they tried to reach

mother at multiple different phone numbers, through text messages, and via email, but

mother was often unresponsive. Mother also missed scheduled meetings to discuss the

case plan with social workers in July, October, November, and December 2024. And

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mother failed to appear at scheduled court hearings in May and September 2024, where the

case plan was discussed. Given the record here, we conclude that the district court’s

finding that the county collaborated with mother “to the degree possible” in selecting

services for mother is not clearly erroneous. See J.H., 968 N.W.2d at 601.

To persuade us otherwise, mother identifies one instance in June 2024 when she

requested a meeting with social worker P.B. and the social worker responded by texting

mother some information instead of scheduling a meeting. However, the record also shows

that soon after this request, a new social worker, K.S., was assigned to mother’s case. In

July 2024, K.S. contacted mother to set up a meeting to review the case plan and also sent

mother another copy of the case plan. After multiple attempts to reach mother and set up

a meeting time, social worker K.S. met with mother in October 2024. Overall, the record

supports the district court’s determination that the county repeatedly tried to coordinate

services in collaboration with mother, but that mother was resistant to these efforts.

Accordingly, substantial evidence supports the district court’s findings that the

county collaborated with mother “to the degree possible” and gave her “a meaningful

opportunity to address the issues” leading to the child’s out-of-home placement. The

district court’s findings related to the county’s attempts to select services in collaboration

with the family are not clearly erroneous, and the district court did not abuse its discretion

by determining that the county’s actions were reasonable.

Visitation with the Child

Mother next argues that the district court erred when it found that the county’s

reunification efforts were reasonable because mother was not permitted to have visitation

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with the child after the case was remanded. She claims that failure to allow contact between

mother and the child “call[s] the adequacy of the efforts to reunify into question.” The

county responds that the district court’s finding that the county made reasonable efforts at

reunification is not clearly erroneous even in the absence of visitation. The county

emphasizes that the limit on visitation was imposed by the district court—not the county—

and persisted due to mother’s actions and inability to demonstrate sobriety.

Generally, once a child is placed outside of the home and in foster care as part of a

CHIPS proceeding, the district court must “review and either modify or approve the

[county’s] plan for supervised or unsupervised visitation.” Minn. Stat. § 260C.201, subd. 5

(2024) (discussing visitation rights). But a district court may deny visitation if it finds that

visitation “is not in the child’s best interests.” Id. The juvenile-protection statute defines

“best interests” to include “all relevant factors to be considered and evaluated.” Minn. Stat.

§ 260C.511(a) (2024).

Here, the record reflects that the district court held a hearing in April 2024 following

remand to discuss the reopened CHIPS matter. At the hearing, the parties addressed the

question of visitation, which had been suspended in 2023 due to concerns about the child’s

well-being. Mother requested that visitation with the child begin soon. The GAL objected

to the request and opposed any visits until mother demonstrated sobriety. The county also

objected to visitation at that time. The district court denied mother’s request for visitation

and ordered mother “to demonstrate sobriety, work towards completing her various

assessments, and begin working her case plan before her visits could commence.” The

parties revisited the question of visitation at a hearing in November 2024. The district

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court again denied mother’s visitation request. The district court also ordered that the

question of visitation be revisited if mother demonstrated sobriety and upon approval of

the child’s therapist.

Because mother did not meet the conditions of visitation set forth in the district

court’s orders, mother did not have visitation with the child following remand. In its

termination order, the district court addressed the issue of visitation and found that “mother

did not substantially engage in her case plan to progress to a point where she could

participate in visitation with her child.”

On appeal, mother acknowledges that Minnesota courts “have not adopted a bright

line rule regarding the provision of visitation prior to termination of parental rights.”

Nevertheless, mother argues that it is “problematic” to withhold visitation from a parent in

light of legislative intent and Minnesota caselaw.

In support of her argument, she cites to In re Welfare of M.A., 408 N.W.2d 227

(Minn. App. 1987), rev. denied (Minn. Sept. 18, 1987). In that case, the county—not the

district court—suspended mother’s visitation rights based on the children’s psychologist’s

report stating that the children had a negative reaction to mother during visits. Id. at 230.

On appeal from the termination of mother’s parental rights, we reviewed whether the

district court’s determination that reasonable efforts by the county failed to correct the

conditions leading to the petition. Id. at 235. We stated that “[r]easonable reuniting efforts

were badly crippled by the [county’s] decision to proceed without visitation” between

mother and the children. Id. at 236. We noted that there was only a “single comprehensive

evaluation of the mother’s needs and abilities,” which cast doubt on whether the county’s

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efforts went “beyond mere matters of form . . . to include real, genuine help.” Id.

(quotation omitted). Despite these concerns, we affirmed the district court order

terminating mother’s parental rights based on mother’s unfitness. Id. at 232-33.

Here, unlike in M.A., the county made genuine efforts to reunify mother with the

child, including offering her services to help achieve sobriety. And here, it was the district

court—not the county—that withheld visitation until mother could maintain sobriety and

the child’s therapist approved of visitation. The district court’s decision to delay visitation

was based on the child’s best interests, following multiple efforts by county social workers

to assist mother in becoming sober, address her mental-health needs, and develop parenting

skills. The record further demonstrates that the county’s efforts went “beyond mere matters

of form so as to include real, genuine assistance.” S.W., 727 N.W.2d at 150 (quotation

omitted). For these reasons, M.A. is distinguishable.

We therefore conclude that the district court did not clearly err in finding that the

county put forth reasonable rehabilitation and reunification efforts, notwithstanding the

lack of visitation between mother and the child.

Problem Presented

Mother also challenges the district court’s finding that the county made reasonable

efforts to rehabilitate mother and reunify the family by arguing that the county’s efforts

were not tailored to address her specific needs in relation to the child’s medical care and

educational needs. In response, the county argues that mother had multiple opportunities

to participate in the child’s medical appointments and services but repeatedly failed to

engage with the child’s needs.

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 Whether the county provided reasonable efforts requires a context-specific analysis

that “depends on the problem presented.” See In re Welfare of S.Z., 547 N.W.2d 886, 892

(Minn. 1996). Here, the district court found that the county provided reasonable efforts to

support mother and reunite the family, specifically finding that the efforts were “tailored

to the individualized needs of the family” and were “adequate to meet the needs of the child

and family.” The record provides ample support for these findings. For example, in

February 2024, a social worker told mother that her authorization was needed for an

updated educational assessment for child, but mother did not provide timely authorization

for this assessment. Mother likewise failed to provide authorization for the child to engage

in psychological testing in March 2024. At trial, mother denied that the child had a

disability or needed resources. She testified that she did not want to authorize certain

services because she did not want the child to be “labeled as needing services” if they were

not required. Given this record, we agree with the district court that the county made

reasonable efforts to address the problem presented in terms of engaging mother in the

child’s medical care and educational needs. See id.

In arguing otherwise, mother identifies two cases to support her assertion that the

county failed to provide adequate efforts to assist her in relation to the child’s medical and

educational needs. Neither case alters our conclusion. Mother first points to In re Welfare

of K.P.C., in which we determined that parental rights cannot be terminated solely based

on a parent’s financial condition. 366 N.W.2d 711, 714 (Minn. App. 1985) (stating that

“mere poverty” is “seldom, if ever,” a sufficient ground for termination (quotations

omitted)). But, because mother does not contend that her parental rights were terminated

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based on her financial situation, this case does not assist our analysis. Mother also relies

on a nonprecedential decision, In re Welfare of Child of E.C.S., in which we concluded that

termination was inappropriate because the parent substantially completed more than 20

requirements in the case plan, including maintaining sobriety. No. A18-2106, 2019 WL

2262324, at *5, 8 (Minn. App. May 28, 2019). Here, mother does not contend that she

substantially complied with the majority of her case plan, as in E.C.S. Nor does she contend

that she has maintained sobriety. This case is also unpersuasive.

In sum, substantial evidence supports the district court’s findings that the county

provided reasonable efforts to rehabilitate mother and reunify the family, and those

findings are not clearly erroneous. The caselaw relied on by mother to argue otherwise is

inapposite. The district court did not abuse its discretion when it determined that the

county’s efforts were reasonable.

II. Clear and convincing evidence supports at least one of the statutory grounds
relied on by the district court to terminate mother’s parental rights.

Mother also argues that we should reverse the district court’s decision terminating

her parental rights because none of the four statutory grounds found by the district court

are supported by the record. We disagree.

To terminate parental rights, at least one statutory ground to involuntarily terminate

parental rights must be present. Minn. Stat. § 260C.301, subd. 1(b) (listing statutory bases

to involuntarily terminate parental rights). When reviewing a district court’s determination

that the county has established one or more statutory grounds, appellate courts “review the

district court’s findings of the underlying or basic facts for clear error, but we review its

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determination of whether a particular statutory basis for involuntarily terminating parental

rights is present for an abuse of discretion.” In re Welfare of Child. of J.R.B., 805 N.W.2d

895, 901 (Minn. App. 2011), rev. denied (Minn. Jan. 6, 2012). If the child to whom parental

rights may be terminated is not an Indian child, a district court must find the relevant facts

by clear and convincing evidence. Minn. R. Juv. Prot. P. 58.03, subd.2(a). If an appellate

court affirms the district court’s decision that one statutory ground to involuntarily

terminate parental rights is present, we need not address whether the other statutory

grounds are supported by the record. See J.K.T., 814 N.W.2d at 92 (recognizing that

appellate courts “need only one properly supported statutory ground in order to affirm a

termination order”).

Here, the district court determined that the county proved by clear and convincing

evidence that four separate statutory grounds supported termination of mother’s parental

rights. Those statutory grounds were: (1) mother substantially, continuously, or repeatedly

failed to comply with the duties imposed upon her by the parent and child relationship;

(2) mother was palpably unfit to parent; (3) despite the county’s reasonable efforts, mother

failed to correct the conditions leading to the child’s out-of-home placement; and (4) the

child was neglected and in foster care. See Minn. Stat. § 260C.301, subd. 1(b)(2), (3), (4),

(7).

We limit our analysis to the third statutory ground found by the district court because

the record reflects that there is clear and convincing evidence to support termination on

that statutory ground. See id., subd. 1(b)(4). Because at least one of the statutory grounds

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found by the district court is supported by the record, we need not address the remaining

statutory grounds for termination. See J.K.T., 814 N.W.2d at 92.

Under section 260C.301, subdivision 1(b)(4), a district court may terminate a

parent’s rights if “following the child’s placement out of the home, reasonable efforts,

under the direction of the court, have failed to correct the conditions leading to the child’s

placement.” Minn. Stat. § 260C.301, subd. 1(b)(4). It is presumed that reasonable efforts

have failed upon a showing that: (1) a child under the age of eight “has resided out of the

parental home under court order for six months unless the parent has maintained regular

contact with the child and the parent is complying with the out-of-home placement plan”;

(2) “the court has approved the out-of-home placement plan”; (3) the “conditions leading

to the out-of-home placement have not been corrected,” which is presumed when the parent

has “not substantially complied with the court’s orders and a reasonable case plan”; and

(4) “reasonable efforts have been made by the [county] to rehabilitate the parent and reunite

the family.” Id., subd. 1(b)(4)(i)-(iv).

Here, the district court found that each of these four factors were satisfied

because: (1) the child was in out-of-home placement for 391 days after remand, and 1,168

days in total; (2) the district court approved a case plan following remand; (3) mother failed

to correct the conditions identified in the case plan—namely, chemical dependency and

mental-health needs—that led to the out-of-home placement; and (4) the county made

reasonable efforts to rehabilitate mother and reunite the family, which included “several

methods to induce and encourage case plan involvement” but “[n]one of these methods

have brought any success, growth, or compliance.”

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 Mother challenges only the district court’s findings on the fourth factor—the county

made reasonable efforts to rehabilitate mother and reunite the family. She does not

challenge the other three factors. Here again, mother focuses on the lack of visitation with

child, arguing that “withholding visitation from mother rendered the efforts to reunify the

family unreasonable.”

For the reasons discussed in the previous section, we conclude that the district

court’s finding that the county made reasonable efforts is supported by substantial evidence

and is not clearly erroneous. And we further conclude that the district court did not abuse

its discretion in determining that a statutory basis for involuntarily terminating mother’s

parental rights was present. As we explained above, it was the district court—not the

county—that restricted visitation based on the child’s best interests until after mother

demonstrated sobriety and the child’s therapist approved. The record reflects that neither

condition was met. We therefore reject mother’s contention that the lack of visitation with

the child after remand provides a basis for concluding that the district court abused its

discretion when it found that clear and convincing evidence supports termination because

reasonable efforts by the county failed to correct the conditions leading to the child’s out-

of-home placement.

To convince us otherwise, mother relies on three cases: In re Child of E.V.,

634 N.W.2d 443 (Minn. App. 2001), In re Forrest, 246 N.W.2d 854 (Minn. 1976), and

M.A., 408 N.W.2d at 227. None of these cases compel reversal.

In E.V., mother challenged the termination of her parental rights. 634 N.W.2d at

445. We reversed and remanded, determining that the district court’s findings were

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“conclusory” and did not properly address whether mother corrected the conditions that

led to out-of-home placement. Id. at 447-49. We cautioned that “[t]he grave danger in

these incomplete and conclusory findings is that the [district] court will find merely ‘no

compliance with the case-plan’ without finding that these failures demonstrate cause for

terminating parental rights.” Id. at 448-49. Here, mother argues that the child was removed

from her care after the CHIPS proceeding because of her failure to demonstrate sobriety,

but that the termination decision was based on her “lack of [a] relationship with the child”

resulting from lack of visitation. This argument is not consistent with the district court’s

order. In its thorough, detailed order, the district court found that termination was

appropriate under subdivision 1(b)(4) because mother failed to correct the conditions

requiring out-of-home placement—her chemical dependency and mental-health needs—

even with reasonable efforts by the county. Contrary to mother’s suggestion, the district

court did not base its decision under subdivision 1(b)(4) on mother’s lack of a relationship

with the child. And because the district court made detailed findings here—unlike the

“conclusory” findings in E.V.—this case does not support reversal.

Mother also relies on Forrest. 246 N.W.2d at 854, 857. In Forrest, the county

appealed the district court’s decision denying the termination of father’s parental rights on

the basis that reasonable efforts had failed to correct the conditions leading to out-of-home

placement. Id. The district court declined to terminate father’s parental rights because

father had demonstrated sobriety and thereby corrected the condition that led to the

placement. Id. But the district court ruled that father was not prepared to assume custody

of the child, and expressed doubts about whether father would ever be in a position to

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assume care and custody of his child because of father’s “age and past history.” Id. The

supreme court concluded that the district court’s findings were unclear on whether father

would be able to care for his child within the foreseeable future based, in part, on the lack

of visitation between parent and child. Id. For that reason, the case was remanded for

explicit findings on that question. Id.

Mother seems to argue that Forrest instructs that a district court cannot terminate

parental rights without giving the parent an opportunity to interact with the child after an

out-of-home placement. Mother’s reliance on Forrest is misguided for two reasons. First,

in Forrest, the district court’s findings were “unclear” on whether father would be able to

provide proper care for the child and become a suitable parent in the foreseeable future.

Id. Here, by contrast, the district court specifically found that “mother is not capable of

caring for [the child] in the reasonably foreseeable future and if the child were returned to

her, [the child] would be placed at risk of instability, harm, and neglect.” Mother does not

challenge this finding. Second, and equally as important, mother did not correct the

conditions that led to the out-of-home placement whereas, in Forrest, the parent did.

Therefore, Forrest does not support reversal of the district court’s determination under

subdivision 1(b)(4).

Finally, mother relies on M.A. 408 N.W.2d at 227. Mother argues that, under M.A.,

withholding visitation renders a county’s efforts to reunify the family unreasonable. As

discussed above, M.A. is distinguishable because the county—not the district court—

suspended the parent’s visitation rights in that case. Id. at 230. Further, the county in this

case made real, genuine efforts to rehabilitate mother and reunify her with the child, further

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distinguishing mother’s circumstances from M.A. Id. at 236 (determining that the county

failed to provide relevant services to support reunification between mother and one child,

but affirming overall decision to terminate parental rights on the basis of mother’s

unfitness). For these reasons, M.A. is not persuasive.

In sum, we conclude that mother has not demonstrated that the district court clearly

erred in finding that the county proved by clear and convincing evidence that mother failed

to correct the conditions that led to the child’s out-of-home placement following reasonable

efforts by the county as required by section 260C.301, subdivision 1(b)(4). We further

conclude that the district court did not abuse its discretion in determining that termination

of mother’s parental rights is supported by at least one statutory basis.

III. The district court did not abuse its discretion by determining that termination
was in the child’s best interests.

Even if a statutory basis for termination is present and the county has made

reasonable efforts, the child’s best interests are the “paramount consideration” in a

termination proceeding. Minn. Stat. § 260C.301, subd. 7; see also Minn. Stat. § 260C.001,

subd. 2(a) (2024) (“The paramount consideration in all juvenile protection proceedings is

the health, safety, and best interests of the child.”). A district court may not terminate

parental rights if termination is not in the best interests of the child. See In re Welfare of

the Child of D.L.D., 771 N.W.2d 538, 545 (Minn. App. 2009) (“Considering a child’s best

interests is particularly important in a TPR proceeding because a child’s best interests may

preclude terminating parental rights even when a statutory basis for termination exists.”

(quotation omitted)). In considering the child’s best interests, the district court must

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analyze three factors: (1) “the child’s interest in preserving the parent-child relationship”;

(2) “the parent’s interests in preserving the parent-child relationship; and” (3) “any

competing interests of the child.” Minn. R. Juv. Prot. P. 58.04(c)(2)(ii); see also J.R.B.,

805 N.W.2d at 905 (“Competing interests [of the child] include such things as a stable

environment, health considerations and the child’s preferences.” (quotation omitted)). We

review a district court’s best-interests determination for an abuse of discretion. J.R.B.,

805 N.W.2d at 905.

The district court made findings of fact on the best interests factors that are

supported by clear and convincing evidence, and that those factors show that termination

was in the best interests of the child. In considering the relevant factors, the district court

found that the child “spent a substantial amount of her life” out of mother’s care, has “built

a strong bond” with her foster parents, “and has made noticeable gains and changes during

her time out of [mother’s] care.” It also found that mother failed to address her mental

health and continued to prioritize her own needs over the needs of the child. The district

court credited the testimony from the social workers and the GAL that termination was in

the child’s best interests because mother could not prioritize the needs of the child, which

would negatively impact the child’s development. Finally, the district court found that “the

[c]hild’s unique needs require and deserve vigilance, consistency, commitment, and a

child-centric approach”; qualities that mother has not been able to demonstrate and would

not be able to demonstrate in the foreseeable future. The district court acknowledged that

the child had “an interest in maintaining a relationship with her biological parent.” And it

credited mother’s testimony that she “continues to care deeply for her [c]hild.” On balance,

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however, the district court determined that the child’s needs and interests outweighed

mother’s desire for reunification.

To convince us that the district court abused its discretion in its analysis of the

child’s best interests, mother contends that the district court could not adequately evaluate

the child’s best interests because mother did not have visitation with the child after the case

was remanded. Mother argues that without visitation, “there was no evidence for the

[district] court to base its best interests determination related to the child’s interest in

maintaining the parent-child relationship.” Mother also asserts that foster mother “has a

stake in the outcome,” and that the child “is too young to express a preference.” We are

not persuaded that these arguments entitle mother to relief. On the contrary, the trial

testimony supports the district court’s findings on the best-interests factors. And on review,

an appellate court will not reweigh the evidence or substitute our judgment for that of the

district court. Sefkow v. Sefkow, 427 N.W.2d 203, 210 (Minn. 1988); see also

Vangsness v. Vangsness, 607 N.W.2d 468, 477 (Minn. App. 2000) (noting that in the

context of child-custody matters, the law “leaves scant if any room for an appellate court

to question the [district] court’s balancing of best-interests considerations”). Therefore,

because the record supports the district court’s findings on the best interests factors, and

because the district court’s balancing of its findings on those factors carefully weighed the

competing interests of the child and mother in making its best-interests findings, we discern

no abuse of discretion in its determination that the child’s best interests favors termination.

Appellant has not shown that the district court abused its discretion in any of its

rulings on the prerequisites for involuntarily terminating her parental rights—reasonable

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efforts to reunite the family, the existence of a statutory basis to terminate parental rights,

best interests of the child. Accordingly, we conclude that the district court did not abuse

its discretion by terminating mother’s parental rights to the child, and we affirm. 1

Affirmed.

1
Mother also asserts that the district court made a number of erroneous factual findings
and credibility determinations. The existence of evidence that could support alternative
findings does not compel reversal, Vangsness, 607 N.W.2d at 474, and there is evidence in
the record supporting the district court’s factual findings and credibility determinations.
We therefore reject these assertions of error.

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