In Re Term of Parental Rights as to J.T.

Court of Appeals of Arizona·Decided June 5, 2026·No. 1 CA-JV 25-0192·Unpublished·Veronika Fabian

Opinion

NOTICE: NOT FOR OFFICIAL PUBLICATION. UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.

IN THE ARIZONA COURT OF APPEALS DIVISION ONE

IN RE TERMINATION OF PARENTAL RIGHTS AS TO J.T.

No. 1 CA-JV 25-0192 FILED 06-05-2026

Appeal from the Superior Court in Maricopa County No. JD41930 No. JS22542 The Honorable Keith A. Miller, Judge

AFFIRMED

COUNSEL

Maricopa County Legal Defender’s Office, Phoenix By Jamie R. Heller Counsel for Appellant Mother

Arizona Attorney General’s Office, Tucson By Marika J. Hodge Counsel for Appellee Department of Child Safety IN RE TERM OF PARENTAL RIGHTS AS TO J.T. Decision of the Court

MEMORANDUM DECISION

Judge Veronika Fabian delivered the decision of the Court, in which Presiding Judge Michael J. Brown and Chief Judge Randall M. Howe joined.

F A B I A N, Judge:

¶1 Martina T. (“Mother”) appeals from the juvenile court’s order terminating her parental rights to J.T. (“Child”). She argues the Department of Child Safety (“DCS”) did not make diligent reunification efforts and the termination of her parental rights was not in Child’s best interests. Because Mother has not shown the juvenile court erred, this Court affirms.

FACTUAL AND PROCEDURAL BACKGROUND

¶2 This Court views the record “in the light most favorable to upholding the juvenile court’s findings.” Brionna J. v. Dep’t of Child Safety, 255 Ariz. 471, 479 ¶ 32 (2023).

¶3 Mother is the biological parent of Child, born in September 2014. In May 2022, DCS received a report that Mother, while intoxicated, 1

had acted aggressively towards Child and the maternal grandmother (“Grandmother”). During a subsequent interview, Grandmother described Mother as having untreated mental health problems, which had resulted in prior domestic violence incidents.

¶4 When DCS interviewed Mother, she was unable to hold a coherent conversation and denied any mental illness. However, she did acknowledge engaging in domestic violence towards Grandmother. The investigator determined Mother’s untreated mental health and substance abuse presented a threat to Child’s safety. DCS took temporary custody of Child and filed a dependency petition.

¶5 The juvenile court found Child dependent as to Mother, concluding that Mother behaved erratically, failed to acknowledge any need for mental health treatment, and had mental health difficulties that

1 The juvenile court terminated the father’s parental rights pursuant to

A.R.S. § 8-533(B)(9), and he is not a part of this appeal.

2 IN RE TERM OF PARENTAL RIGHTS AS TO J.T. Decision of the Court

may be aggravated by alcohol abuse. The court adopted a family reunification case plan.

¶6 During the dependency, DCS offered Mother reunification services including case management, supervised visitation, substance abuse treatment, drug testing, a psychological evaluation, individual counseling, and parenting and domestic violence classes through Family Connections. Because Mother denied any substance abuse or mental health problems and refused to drug test, she was unable to be assessed for treatment.

¶7 Mother’s visits with Child were supervised for most of the dependency because Mother sometimes threatened the supervisors, made inappropriate comments, or indicated she would abscond with Child.

¶8 In February 2024, Mother went to the emergency room for suicidal thoughts. She denied drinking, but her blood alcohol concentration was 0.287. While hospitalized, she acknowledged a history of alcohol abuse and a high tolerance for alcohol. In March 2024, she was discharged and admitted into residential treatment, where she remained until June 2024.

¶9 After leaving residential treatment, Mother began to engage with services and make progress. She started individual counseling and online parenting, anger management, and domestic violence classes. In November and December 2024, Mother began unsupervised and then overnight visits.

¶10 During Child’s first overnight visit, a conflict arose when Mother insisted on washing Child’s hair in the shower. DCS slowed the transition and determined the family would benefit from family counseling regarding age-appropriate boundaries.

¶11 Before family counseling could occur, Mother was arrested for assaulting a neighbor and then placed in court-ordered treatment. After this incident, DCS stopped Child’s unsupervised visits with Mother, ending the transition plan. In April 2025, DCS held a team decision-making meeting and decided to request a change in case plan to termination and adoption. Although Child was initially very upset, after therapy, he understood DCS’s concerns for his safety and did not continue to show emotional distress.

¶12 The juvenile court granted DCS’s request to change the case plan to termination and adoption. DCS then moved to terminate Mother’s

3 IN RE TERM OF PARENTAL RIGHTS AS TO J.T. Decision of the Court

parental rights based on chronic substance abuse, mental illness, and 15- months out-of-home placement. A.R.S. § 8-533(B)(3), (8)(c).

¶13 At the termination hearing, the case manager testified Mother had not remedied the circumstances that kept Child in DCS custody for three years—specifically, her failure to demonstrate sobriety and stable mental health. She also testified termination would provide Child permanency and stability through adoption, but noted Child did not want Mother’s rights terminated. A psychologist who had evaluated Mother testified that her lack of recognition of her behavioral or substance abuse problems was the fundamental issue, and that her inability to stop drinking despite her sincere desire to reunify met the definition of alcohol abuse.

¶14 The juvenile court terminated Mother’s parental rights on chronic substance abuse and the 15-months out-of-home placement grounds. It found that DCS made reasonable and diligent efforts to provide Mother with appropriate reunification services. The court concluded that terminating Mother’s parental rights was in Child’s best interests despite the bond between them because it would provide permanency and stability through adoption.

¶15 Mother timely appealed. This Court has jurisdiction under A.R.S. §§ 8-235(A), 12-120.21(A)(1) and -2101(A)(1), and Arizona Juvenile Court Rule of Procedure 601(a).

DISCUSSION

¶16 Mother challenges the juvenile court’s findings that DCS made diligent efforts to provide her with appropriate reunification services and that the termination of her parental rights was in Child’s best interests.

¶17 “Parents have a fundamental right, protected by the Fourteenth Amendment, to the ‘care, custody, and control of their children.’” Borja v. Borja, 254 Ariz. 309, 313 ¶ 8 (App. 2022) (quoting Troxel v. Granville, 530 U.S. 57, 65 (2000)). But that right is not absolute. Michael J. v. Ariz. Dep’t of Econ. Sec., 196 Ariz. 246, 248 ¶¶ 11–12 (2000). To terminate a parent-child relationship, the juvenile court must find that: 1) a statutory ground for termination under A.R.S. § 8-533(B) exists by clear and convincing evidence and 2) termination is in the child’s best interests by a preponderance of the evidence. Brionna J., 255 Ariz. at 477 ¶ 20.

Free access — add to your briefcase to read the full text and ask questions with AI

In Re Term of Parental Rights as to J.T., (Ark. Ct. App. 2026).

In Re Term of Parental Rights as to J.T. (In Re Term of Parental Rights as to J.T.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Troxel v. Granville
530 U.S. 57 (Supreme Court, 2000)
Michael J. v. Arizona Department of Economic Security
995 P.2d 682 (Arizona Supreme Court, 2000)
In Re the Appeal in Maricopa County Juvenile Action No. JS-501904
884 P.2d 234 (Court of Appeals of Arizona, 1994)
Demetrius L. v. Joshlynn F./d.L.
365 P.3d 353 (Arizona Supreme Court, 2016)
Dominique M. v. Department of Child Safety
376 P.3d 699 (Court of Appeals of Arizona, 2016)
Donald W. v. Dcs, M.D.
444 P.3d 258 (Court of Appeals of Arizona, 2019)
Mary Lou C. v. Arizona Department of Economic Security
83 P.3d 43 (Court of Appeals of Arizona, 2004)