(1) Per 10A O.S.
§ 1-4-904, a court may not terminate a parent's parental rights unless the
child is adjudicated deprived prior to, or concurrent with, TPR proceedings,
and the court makes the finding that TPR is in the child's best
interests.
(2) Per 10A O.S. §
1-4-901, a TPR petition or motion may be filed by the district attorney (DA) or
by the attorney for the child alleged to be or adjudicated deprived.
(3) Per 10A O.S. § 1-4-904, the court
may terminate parental rights on the grounds listed in (A) through (Q) of this
paragraph.
(A)
Consent. The
parent may consent to termination of his or her parental rights by signing a
voluntary consent form to relinquish parental rights.
(i) The written, voluntary consent signed
under oath, recorded before a judge of a court of competent jurisdiction, is
not revocable unless the parent can provide clear and convincing evidence that
the consent was executed by reason of fraud or duress.
(ii) In any proceeding for a voluntary TPR to
an Indian child, the parent's consent may be withdrawn for any reason at any
time prior to the entry of a final decree of termination. Any consent given
prior to or within 10-calendar days after the birth of the Indian child is not
valid.
(B)
Abandonment. The court may find that the parent who is entitled to
custody of the child has abandoned the child.
(C)
Abandonment of an Infant.
The court may find that the child, 12 months of age and younger, was
abandoned.
(D)
Non-compliance
with voluntary placement agreement. The court may find that the child's
parent:
(i) voluntarily placed physical
custody of the child with Oklahoma Human Services (OKDHS) or a child-placing
agency for out-of-home placement;
(ii) has not complied with the placement
agreement; and
(iii) during the
child's period of voluntary out-of-home placement, has not demonstrated a firm
intent to resume physical custody of the child or make other permanent legal
arrangements for the child's care.
(E)
Failure to correct
condition(s). The court may find that the parent failed to correct the
condition(s) that led to the child's adjudication as a deprived child although
the parent was given at least three months to correct the
condition(s).
(F)
Same
conditions - another child. The court may find that another child of a
parent whose parental rights to any other child were terminated and the
conditions that led to the prior TPR were not corrected.
(G)
Failure to support. The
court may find that the non-custodial parent has willfully failed, refused, or
neglected to contribute to the child's support for at least six out of the last
12 months immediately preceding the filing of the termination petition or
motion:
(i) as specified by a court order for
child support, or
(ii) according to
the parent's financial ability to support the child, when an order for child
support does not exist. Incidental or token support is not construed or
considered when determining if the parent maintained or contributed to the
child's support.
(H)
Certain criminal convictions. The court may find a parent has a
conviction in a criminal action, in any state, of any of the following acts:
(i) permitting a child to participate in
pornography;
(ii) rape or rape by
instrumentation;
(iii) lewd
molestation of a child younger than 16 years of age;
(iv) child abuse or neglect;
(v) enabling child abuse or
neglect;
(vi) causing the death of a
child as a result of the physical or sexual abuse, chronic abuse, or chronic
neglect of the child;
(vii) causing
the death of the child's sibling as a result of the physical or sexual abuse,
chronic abuse, or chronic neglect of the child's sibling;
(viii) murder of any child or aiding or
abetting, attempting, conspiring, or soliciting to commit murder of any
child;
(ix) voluntary manslaughter
of any child;
(x) a felony assault
that resulted in serious bodily injury to the child or another child of the
parents; or
(xi) murder or
involuntary manslaughter of the child's parent or aiding or abetting,
attempting, conspiring, or soliciting to commit murder of the child's
parent.
(I)
Heinous
or shocking abuse or neglect. The court may find that a parent has
abused or neglected any child or failed to protect any child from abuse or
neglect that is heinous or shocking.
(J)
Prior abuse or neglect. The
court may find that a parent previously abused or neglected the child or the
child's sibling, or failed to protect the child or sibling from abuse or
neglect and the child or sibling was subjected to subsequent abuse.
(K)
Rape by the parent. The
court may find the child was conceived as a result of a rape perpetrated by the
parent whose rights to the child are sought to be terminated.
(L)
Incarceration. While a
parent's incarceration in and of itself is not sufficient to deprive a parent
of parental rights, the court may find continued parental rights of an
incarcerated parent whose rights are sought to be terminated would result in
harm to the child based on the consideration of factors including, but not
limited to, the:
(i) duration of
incarceration and its detrimental effect on the parent-child relationship;
(ii) previous convictions resulting
in involuntary confinement in a secure facility;
(iii) history of criminal behavior, including
crimes against children;
(iv) the
child's age;
(v) evidence of abuse
or neglect or failure to protect the child or the child's siblings by the
parent;
(vi) current relationship
between the parent and child; and
(vii) manner in which the parent exercised
parental rights and duties in the past.
(M)
Behavioral health illness or
incapacity. The court must find the factors in (i) and (ii) of this
subparagraph exist.
(i) The parent has a
diagnosed cognitive disorder, an extreme physical incapacity, or a medical
condition, including behavioral health or substance dependency, that renders
the parent incapable of adequately and appropriately exercising parental
rights, duties, and responsibilities within a reasonable time, considering the
child's age. A finding that a parent has a diagnosed cognitive disorder, an
extreme physical incapacity, or a medical condition, including behavioral
health or substance dependency, does not in and of itself deprive the parent of
parental rights.
(ii) Allowing the
parent to have custody would cause the child actual harm or harm in the near
future. A parent's refusal or non-compliance with treatment, therapy,
medication, or assistance for the condition can be used as
evidence.
(N)
Prior
adjudication of same conditions. The court may find the:
(i) condition that led to the deprived
adjudication was the subject of a previous deprived adjudication of this child
or this child's sibling; and
(ii)
parent was given an opportunity to correct the conditions that led to the
determination of the initial deprived child.
(O)
Substantial erosion of parent-child
relationship. The court may find a substantial erosion of the
relationship between the parent and child exists caused at least in part by:
(i) the parent's serious or aggravated
neglect of the child, physical or sexual abuse, or sexual exploitation of the
child;
(ii) a prolonged and
unreasonable absence of the parent from the child; or
(iii) the parent's unreasonable failure to
visit or communicate in a meaningful way with the child.
(P)
Lengthy foster care of child years
of age and older.
(i) The court may
find:
(I) a child years of age and older at
the time of placement was placed in foster care by OKDHS for 15 of the most
recent 22 months preceding the filing of the TPR petition or motion;
and
(II) at the time of the filing
of the TPR petition or motion, the child cannot be safely returned to the home
of the parent.
(ii) A
child is considered to have entered foster care on the earlier of the:
(I) adjudication date; or
(II) date 60-calendar days after the date the
child was removed from his or her home.
(Q)
Lengthy foster care of a child
younger than 4 years of age.(i) The
court may find a child younger than 4 years of age at the time of placement:
(I) was placed in foster care by OKDHS for at
least six of the 12 months preceding the filing of the TPR petition or motion;
and
(II) the child cannot be safely
returned to the home of the parent.
(ii) A child is considered to have entered
foster care on the earlier of the:
(I)
adjudication date; or
(II) date
60-calendar days after the date the child was removed from his or her
home.
(iii) The court may
consider:
(I) circumstances of the parent's
failure to develop and maintain a parental bond with the child in a meaningful,
supportive manner; and
(II) if
allowing the parent to have custody would likely cause the child actual serious
psychological harm or harm in the near future as a result of the child's
removal from the substitute caregiver due to the existence of a strong,
positive bond between the child and
caregiver.