In re James O., Jr.

Summary

The concurrence would affirm the termination judgment despite concluding that the trial court improperly compared the respondent mother with the foster mother during the adjudicatory phase. It reasons that the error was harmless because the trial court made extensive, independent findings that the respondent had failed to rehabilitate. The concurrence also explains that harmless-error analysis applies even if the impropriety constituted a due process violation.