In re Interest of Jessalina M.

Summary

The court affirmed termination of Samantha M.'s parental rights, holding that Jessalina's placement with her father counted as out-of-home placement as to Samantha and that the statutory 15-of-22-month period is measured when the termination petition or motion is filed. The court also upheld the findings that Samantha was unfit and that termination served Jessalina's best interests, emphasizing that the placement-duration ground alone does not establish either finding.