In re B.M., Juvenile

Summary

The court affirmed termination of the father’s residual parental rights despite his substantial recovery from substance abuse and improved living circumstances. It held that the reasonable-period inquiry is forward-looking, but that the father’s history and the child’s lack of a meaningful relationship with him remained relevant to his prospective ability to parent. The court rejected reliance on psychological testing as the sole basis for termination but found sufficient independent evidence supporting the order.