In the Interest of: W.I.M.P., Juvenile; Juvenile Officer, Respondent, v. R.P. (Mother), Appellant. (2026)

R.P. (“Mother”) appeals from a judgment terminating her parental rights with respect to her child, W.I.M.P (“Child”).¹ Mother argues the evidence presented at trial did not support the statutory bases and the best-interests findings relied on by the trial court to terminate her parental rights. Finding no error, we affirm.

Factual and Procedural Background 2

Mother is the biological parent of Child, who was born in 2015. In October 2023, a non-attendance referral was made to the Juvenile Office regarding Child's poor attendance at school. Mother was offered services to help with parenting education, housing, mental health, and financial assistance. However, as of February 20, 2024, Child had an attendance rate of 39%, attending only eleven full days and twenty-five partial days of school out of a possible ninety-eight days of enrollment. As a result, Child was placed into protective custody and entered foster care on February 29, 2024.

On April 11, 2024, the trial court held a dispositional hearing (“April 2024 dispositional hearing”). Following the hearing, the trial court issued an order of disposition, making Child a ward of the court until the age of eighteen and placing her in the care, custody, and control of the Missouri Children's Division pursuant to sections 211.031.1(1) and 211.183.5(1)-(5).³ The trial court found that Child's removal was necessary to protect her because Mother had failed to ensure Child's regular attendance at school, despite Mother being provided services to address attendance issues. The trial court ordered Mother to pay $50 per month for the support and maintenance of Child; to nurture the bond with Child by maintaining regular contact and providing all necessary supplies during visits; to obtain, maintain, and provide proof of safe, stable housing and all utilities; to obtain and maintain verifiable employment; to attend Child's therapy and doctor appointments; to participate actively in the case; to maintain contact with the Children's Division; to provide the Children's Division and the Juvenile Office with a current address; to sign releases of information for all service, medical, and treatment providers; to submit to all requested drug testing; to complete a psychological evaluation; and to follow any recommendations from the psychological evaluation.

Following dispositional reviews in July and November 2024, the trial court issued findings, determining that Child should remain in the care, custody, and control of the Children's Division. The trial court reiterated the orders from the April 2024 dispositional hearing and further ordered Mother to remain drug free; to attend and complete parenting education; to take care of any and all legal issues; to submit to a hair and nail drug test within twenty-four hours; and to submit proof of living with her adult daughter within seven days.

The trial court held permanency reviews in February and July 2025. Following the reviews, the trial court found that Child should remain in the care, custody, and control of the Children's Division. The trial court found that pursuant to section 210.720, “a permanent plan for the placement of [Child] include[d] continued placement in the care and custody of the Children's Division for placement in alternative care; the case goal is termination of parental rights and adoption with a concurrent goal of guardianship ․” The trial court again restated its orders from the April 2024 dispositional hearing, and further ordered Mother to submit to an observed urinalysis test and nail drug test within twenty-four hours; to install a drug patch within forty-eight hours; to provide proof of Child being sent home from school due to her behavior within seven days; to provide proof of employment within seven days; to provide proof of being on her adult daughter's lease within seven days; and to reengage with a parenting education program within twenty-four hours and provide proof of reengagement.

On June 10, 2025, the Juvenile Officer petitioned to terminate Mother's parental rights with respect to Child. The trial court held a three-day bench trial on the petition beginning on August 21, 2025. Upon the Juvenile Officer's request, the trial court took judicial notice of the underlying child abuse or neglect case and the trial court's findings related to the dispositional and permanency reviews in that case. The trial court received forty-five exhibits, and heard the testimony of eleven witnesses, including a deputy juvenile officer, three caseworkers, a clinical psychologist, the director of a parenting education program, a court-appointed special advocate, and Mother.

The evidence revealed that Mother had come to every hearing in the underlying abuse or neglect case; that she had maintained regular visits with Child; and that she had also consistently stayed in contact with the deputy juvenile officer and the caseworkers from the Children's Division. Despite this consistency, the evidence established that Mother did not comply with the majority of the trial court's orders. Mother had failed to pay $50 per month for Child's care and maintenance; to nurture the bond with Child; to obtain, maintain, and provide proof of safe, stable housing; to obtain, maintain, and provide proof of verifiable employment; to sign releases of information for all service providers; to submit to all requested drug testing; and to follow all recommendations from the psychological evaluation.

On September 22, 2025, the trial court entered its written judgment (“Judgment”) terminating Mother's parental rights on three grounds: abuse or neglect pursuant to section 211.447.5(2); failure to rectify pursuant to section 211.447.5(3); and parental unfitness pursuant to section 211.447.5(5). The trial court further found it to be in the best interests of Child to terminate Mother's parental rights pursuant to section 211.447.7.

Mother appeals. Additional facts relevant to the disposition of the appeal are set forth in the analysis.

Standard of Review

Before terminating parental rights, the trial court must make two findings pursuant to section 211.447.6. Int. of S.K.J., 730 S.W.3d 109, 116 (Mo. App. W.D. 2025). “First, the trial court must find that clear, cogent, and convincing evidence supports at least one of the grounds of termination outlined in section 211.447.” Id. (citing In re S.M.F., 393 S.W.3d 635, 643 (Mo. App. W.D. 2013)). “Evidence is clear, cogent and convincing, if it ‘instantly tilts the scales in favor of termination when weighed against the evidence in opposition and the finder of fact is left with the abiding conviction that the evidence is true.’ ” Id. (quoting In re S.M.F., 393 S.W.3d at 643). On appeal, we will affirm the trial court's judgment finding a statutory basis for terminating parental rights “unless there is no substantial evidence to support it, it is contrary to the evidence, or it erroneously declares or applies the law.” Int. of E.G., 683 S.W.3d 261, 265 (Mo. banc 2024) (quoting In re K.A.W., 133 S.W.3d 1, 11 (Mo. banc 2004)). “Substantial evidence of only one of the grounds for termination is enough to affirm the judgment on appeal.” In re M.J.M., 553 S.W.3d 327, 336 (Mo. App. W.D. 2018) (citing In re Q.A.H., 426 S.W.3d 7, 12 (Mo. banc 2014)). In reviewing whether substantial evidence supported the judgment, “we view the evidence and inferences therefrom in the light most favorable to the [trial] court's judgment, deferring to its credibility determinations and resolutions of conflicts in the evidence.” Id. (citing J.A.R. v. D.G.R., 426 S.W.3d 624, 626 (Mo. banc 2014)). We also recognize that the trial court was “free to disbelieve any, all, or none of the evidence” and that it is not our role to reevaluate the evidence. Id. (quoting J.A.R., 426 S.W.3d at 627).

“Second, if the trial court finds a statutory basis for terminating parental rights, it assesses whether terminating parental rights is in the best interests of the child.” Int. of S.K.J., 730 S.W.3d at 117 (citing In re S.M.F., 393 S.W.3d at 644; section 211.447.6). “At the trial level, the standard of proof for this best interest inquiry is a preponderance of the evidence; on appeal, the standard of review is abuse of discretion.” Id. (quoting In re K.S., 561 S.W.3d 399, 406 (Mo. App. W.D. 2018)). “An abuse of discretion occurs only when the trial court's ruling is clearly against the logic of the circumstances and [is] so unreasonable and arbitrary that it shocks the sense of justice and indicates a lack of careful, deliberate consideration.” Id. (alteration in original) (quoting In re K.S., 561 S.W.3d at 406).

“When the trial court finds multiple statutory grounds for termination of parental rights, we will affirm the judgment if any one of those grounds was proven and termination was in the child's best interests.” Id. (quoting In re A.C.G., 499 S.W.3d 340, 347 (Mo. App. W.D. 2016)).

Analysis

Mother raises six points on appeal, each asserting the trial court erred in terminating her parental rights with respect to Child. Her first, second, third, and fifth points challenge each statutory ground upon which the trial court terminated her parental rights, and her fourth and sixth points challenge the trial court's finding that terminating her parental rights was in the best interests of Child.

In her first point on appeal, Mother contests the trial court's finding regarding the abuse or neglect ground because sufficient evidence did not support that Mother had abused or neglected Child. The second point on appeal further challenges the trial court's finding on the abuse or neglect ground because there was not sufficient evidence to support that Mother has an untreatable chemical dependency preventing her from consistently providing the necessary care, custody, and control of Child. Mother asserts in the third point on appeal that sufficient evidence did not support the trial court's finding on the failure to rectify ground that Mother had failed to complete or provide proof of completion of most of the court-ordered services. The fifth point on appeal contends that there was not sufficient evidence to establish Mother's parental unfitness based on a consistent pattern of committing a specific abuse. In the fourth and sixth points on appeal, Mother argues that sufficient evidence did not support the trial court's finding that the termination of Mother's parental rights was in the best interests of Child.

While all of Mother's points on appeal frame her argument as a matter of the sufficiency of the evidence to support the trial court's findings, the sufficiency-of-the-evidence standard of review is generally used only in criminal cases. See State v. Lammers, 479 S.W.3d 624, 632 (Mo. banc 2016) (“Appellate review of sufficiency of the evidence is limited to whether the State has introduced adequate evidence from which a reasonable finder of fact could have found each element of the crime beyond a reasonable doubt.”) (citation omitted). Notwithstanding the phrasing of the points relied on, we discern that Mother was attempting to assert a not-supported-by-substantial-evidence challenge in each point.⁴

However, such a challenge requires an appellant to complete the following sequential steps pursuant to Houston v. Crider:

(1) identify a challenged factual proposition, the existence of which is necessary to sustain the judgment;

(2) identify all of the favorable evidence in the record supporting the existence of that proposition; and,

(3) demonstrate why that favorable evidence, when considered along with the reasonable inferences drawn from that evidence, does not have probative force upon the proposition such that the trier of fact could not reasonably decide the existence of the proposition.

317 S.W.3d 178, 187 (Mo. App. S.D. 2010); see Int. of K.M.D., 726 S.W.3d 87, 97-98 (Mo. App. W.D. 2025) (applying the Houston v. Crider framework in an appeal from a judgment terminating parental rights). As the Juvenile Officer underscores, Mother failed to follow these steps in developing any of her points on appeal. None of Mother's points direct this Court to any evidence favorable to the trial court's findings that she challenges, and none resolve why the favorable evidence and the reasonable inferences drawn therefrom do not have probative force such that the trial court could not have reasonably made the findings that she challenges. Adherence to the analytical framework for not-supported-by-substantial-evidence challenges “is mandatory because it reflects the underlying criteria necessary for a successful challenge--the absence of any such criteria, even without a court-formulated sequence, dooms an appellant's challenge.” Int. of K.M.D., 726 S.W.3d at 98 (quoting Bell-Kaplan v. Schwarze, 712 S.W.3d 836, 846 (Mo. App. S.D. 2025)).

In addition to highlighting Mother's noncompliance with the steps for not-supported-by-substantial-evidence challenges, the Juvenile Officer asks this Court to dismiss the appeal due to the lack of analytical development in the argument section of Mother's brief and the deficiency of her points relied on, in violation of Rule 84.04. “Rule 84.04 provides the mandatory requirements for briefs filed in all appellate courts.” Int. of K.M.D., 726 S.W.3d at 96 (quoting Int. of S.R.W., 715 S.W.3d 223, 227 (Mo. App. W.D. 2025)). “While it may not be stated explicitly in Rule 84.04, the fundamental requirement for an appellate argument is that it demonstrate the erroneousness of the basis upon which a lower court or agency issued an adverse ruling.” Ireland v. Div. of Emp. Sec., 390 S.W.3d 895, 900 (Mo. App. W.D. 2013) (quoting Rainey v. SSPS, Inc., 259 S.W.3d 603, 606 (Mo. App. W.D. 2008)). “Mere conclusions and the failure to develop an argument with support from legal authority preserve nothing for review.” Id. (quoting Hankins v. Reliance Auto., Inc., 312 S.W.3d 491, 495 (Mo. App. E.D. 2010)). The Juvenile Officer contends that Mother did not follow this requirement because she does not provide sufficient analytical support for her claims of error in the argument section of her brief, as she does not advise this Court how principles of law interact with the facts of the case. Additionally, Rule 84.04(d)(1) requires an appellant's point relied on to “(A) [i]dentify the trial court ruling or action that the appellant challenges; (B) [s]tate concisely the legal reasons for the appellant's claim of reversible error; and (C) [e]xplain in summary fashion why, in the context of the case, those legal reasons support the claim of reversible error.” The Juvenile Officer asserts that Mother's points relied on do not establish all three elements since none of them explain why the claimed legal reasons support the claim of reversible error in the context of the case.

Though the failure to comply with the framework of not-supported-by-substantial-evidence challenges and with Rule 84.04 can be grounds for dismissal, we acknowledge that “[t]ermination of parental rights is an exercise of awesome power” that must be reviewed closely. Int. of A.M.W., 652 S.W.3d 225, 234 (Mo. App. W.D. 2022) (quoting Int. of D.L.S., 606 S.W.3d at 222). “Given the fact that termination of parental rights is ‘one of the most serious acts a court is empowered to perform,’ we choose to exercise our discretion to address the merits of Mother's claims, noting that Mother's briefing deficiencies do not impede our ability to understand most of Mother's arguments on appeal ․” Int. of K.M.D., 726 S.W.3d at 96 (internal quotation and citation omitted) (“Dismissal of an appeal for briefing deficiencies is discretionary, and this discretion is generally not exercised unless the deficiencies impede a disposition of the case on its merits.”).

In reviewing the merits of Mother's claims, we hold that the record supplies substantial evidence to support the termination of Mother's parental rights on the failure to rectify ground, the subject of Mother's third point on appeal. Because “[s]ubstantial evidence of only one of the grounds for termination is enough to affirm the judgment on appeal,” Int. of M.J.M., 553 S.W.3d at 336 (citation omitted), we do not need to address Mother's first, second, and fifth points. We hold that the record further supplies substantial evidence to support the trial court's finding that termination of Mother's parental rights was in the best interests of Child, the subject of Mother's fourth and sixth points on appeal. See Int. of S.K.J, 730 S.W.3d at 117 (“When the trial court finds multiple statutory grounds for termination of parental rights, we will affirm the judgment if any one of those grounds was proven and termination was in the child's best interests.”) (quotation omitted).

Point Three: Substantial evidence supported the trial court's determination that Mother's parental rights should be terminated on the failure to rectify ground

In essence, Mother's third point on appeal asserts that the trial court erred in terminating her parental rights on the failure to rectify ground because the record did not provide substantial evidence to establish that Mother had failed to complete or provide proof of completion of most court-ordered services in the underlying abuse or neglect case. We disagree.

“The termination ground set forth in section 211.447.5(3) is commonly referred to as ‘failure to rectify.’ ” Int. of S.K.J., 730 S.W.3d at 118 (citing Int. of A.M.W., 652 S.W.3d at 235). To terminate parental rights based on the failure to rectify, the trial court must find clear, cogent, and convincing evidence that (1) the child has been under the jurisdiction of the juvenile court for at least a year; (2) the conditions that led to the assumption of jurisdiction persist, or conditions of a potentially harmful nature currently exist; and (3) there is little likelihood that the conditions will be remedied at an early date so that the child can be returned to the parent in the near future, or continuation of the parent-child relationship greatly diminishes the child's prospects for early integration into a stable and permanent home. Section 211.447.5(3). In determining whether to terminate parental rights for failure to rectify, the trial court must also consider and make findings on the following factors:

(a) The terms of a social service plan entered into by the parent and the division and the extent to which the parties have made progress in complying with those terms;

(b) The success or failure of the efforts of the juvenile officer, the division or other agency to aid the parent on a continuing basis in adjusting his circumstances or conduct to provide a proper home for the child;

(c) A mental condition which is shown by competent evidence either to be permanent or such that there is no reasonable likelihood that the condition can be reversed and which renders the parent unable to knowingly provide the child the necessary care, custody and control;

(d) Chemical dependency which prevents the parent from consistently providing the necessary care, custody and control over the child and which cannot be treated so as to enable the parent to consistently provide such care, custody and control ․

Section 211.447.5(3)(a)-(d). While none of these factors constitute a separate ground for termination, “ ‘proof of just one factor is sufficient to support termination of parental rights’ pursuant to section 211.447.5(3).” Int. of S.K.J., 730 S.W.3d at 118 (citation and quotation omitted).

Here, the trial court complied with the requirements of section 211.447.5(3). First, the trial court found that clear, cogent, and convincing evidence supported that Child had been under its jurisdiction for more than one year; the conditions which led to the assumption of jurisdiction still persisted; and conditions of a potentially harmful nature continued to exist. The trial court specifically found that several witnesses testified that the court-ordered services remained the same throughout the underlying abuse or neglect case; the orders were provided to Mother; and Mother did not complete the vast majority of the ordered services. The trial court highlighted that Mother had failed to submit to drug tests either in a timely manner or at all; to install a drug patch; to complete all the assessments in an honest manner during the psychological evaluation; to comply with all recommendations following the psychological evaluation, including completing a parenting education program and participating in individual therapy; to establish and provide proof of safe, stable housing; to establish, maintain, and offer proof of verifiable employment; and to nurture the bond with Child due to Mother using a tablet during visits without otherwise engaging Child.

The trial court then evaluated the four non-exclusive evidentiary factors identified in section 211.447.5(3), concluding that clear, cogent, and convincing evidence supported findings under subsections (a), (b), and (d). Pursuant to subsection (a), the trial court found that clear, cogent, and convincing evidence “showed that [Mother] ha[d] failed to make progress in complying with the terms of social service plans entered into with the Children's Division or comply[ing] with the court ordered services” in the underlying abuse or neglect case. The trial court incorporated its findings from the preceding paragraph that showed Mother had failed to comply with most court-ordered services. Regarding subsection (b), the trial court found that clear, cogent, and convincing evidence established that Mother had “failed to adjust her circumstances and conduct on a continuing basis so that [s]he can provide a proper home for [Child].” The trial court specifically noted that the issues with Child's attendance at school had been resolved since she entered foster care; Mother did not take accountability for Child's attendance issues; Mother had not resolved the issues with unstable housing and employment; Mother had not followed recommendations following the psychological evaluation to complete parenting education and to engage in individual therapy; and Mother had not financially supported Child during the pendency of the case. As to subsection (d), the trial court determined that clear, cogent, and convincing evidence supported that Mother had a chemical dependency preventing her from consistently providing the necessary care, custody, and control of Child, which cannot be treated so as to enable her to consistently provide such care, custody, and control. The trial court incorporated its findings that Mother had a chemical dependency pursuant to section 211.447.5(2)(b).

On appeal, Mother does not challenge the trial court's findings that Child was in the court's jurisdiction for one year; the conditions leading to the assumption of jurisdiction still persisted; and the conditions of a potentially harmful nature continued to exist. She also does not challenge the trial court's findings as to each of the three factors that the trial court found applicable to the case. Mother only challenges the trial court's finding with respect to subsection (a), that she did not make progress in complying with the terms of the social service plan, because she claims that the evidence presented at trial showed she had “completed the vast majority of the court ordered services ․” However, given that “ ‘proof of just one factor is sufficient to support termination of parental rights’ pursuant to section 211.447.5(3),” Int. of S.K.J., 730 S.W.3d at 118, Mother's failure to challenge the trial court's findings as to subsections (b) and (d) is fatal to her point on appeal.

Even if Mother's challenge to the trial court's finding as to only subsection (a) constituted a sufficient claim of error, our review of the record discloses that substantial evidence supported the trial court's finding that Mother failed to make an effort to progress in complying with the social service plan. See In re S.M.H., 160 S.W.3d 355, 368-69 (Mo. banc 2005) (a parent does not need to fully comply with all aspects of the social service plan to avoid termination; but she must make an effort to progress in complying with the social service plan).

In the underlying neglect or abuse case, the trial court ordered Mother to pay $50 per month for the support and maintenance of Child; to nurture the bond with Child by maintaining regular contact and providing all necessary supplies during visits; to obtain, maintain, and provide proof of safe, stable housing and all utilities; to obtain and maintain verifiable employment; to attend Child's therapy and doctor appointments; to participate actively in the case; to maintain contact with the Children's Division; to provide the Children's Division and the Juvenile Office with a current address; to sign release forms for all service, medical, and treatment providers; to submit to all requested drug testing; to complete a psychological evaluation; to follow any recommendations from the psychological evaluation; to remain drug free; to attend and complete parenting education; and to take care of any and all legal issues. In furtherance of these orders, the trial court issued more specific orders for Mother to submit to a hair and nail drug test within twenty-four hours of a review; to submit proof of living with her adult daughter and being on the lease within seven days of a review; to submit to an observed urinalysis test and nail drug test within twenty-four hours of a review; to install a drug patch within forty-eight hours of a review; to provide proof of Child being sent home from school due to her behavior within seven days of a review; to provide proof of employment within seven days of a review; and to reengage with the parenting education program within twenty-four hours of a review and provide proof of reengagement. The evidence presented at trial established that Mother either partially complied or entirely failed to comply with the majority of these court orders, and that she thereby did not make progress in engaging with the court-ordered services that were intended to aid reunification.

As to the trial court's order to pay $50 per month for the care and maintenance of Child, Alison Greco (“Greco”), the deputy juvenile officer on the case, testified that Mother had never paid any support during the pendency of the case. Mother admitted at trial that she had paid no child support. Mother testified that although she had been present at every hearing, she did not know that she owed any support.

Regarding the trial court's order to nurture the bond with Child, the three caseworkers’ testimony revealed that Mother maintained visits with Child throughout the case, but that Mother became less engaged with Child as the case progressed. Riley Dotson (“Dotson”), the caseworker from September 2024 to March 2025, testified that Mother started bringing a tablet to watch movies with Child during visits, and that she did not otherwise engage Child. Nichole Sears (“Sears”), the caseworker from March 2025 through the hearing in August 2025, testified that Mother failed to come to a visit on her birthday after she had promised during the previous visit that she would bring cupcakes to celebrate with Child. Sears testified that this caused Child to have a major meltdown. Sears noticed that after this missed visit, Child's focus shifted away from engaging with Mother to only playing on the tablet during visits. Based on her observations of these visits, Sears testified that while Mother loved and cared about Child, Child seemed to love Mother but did not view her as a parental figure.

Related to the trial court's order to establish safe, stable housing, the caseworkers’ testimony indicated that Mother's housing had been a concern in the case. Susan Barnes (“Barnes”), the caseworker from February to September 2024, testified that Mother had leased an apartment in April 2024, but that a petition for rent and possession of that apartment was filed against Mother by July 2024. Barnes testified that Mother had claimed that she was not being evicted and that it was a “mishap” in the court system due to her filing for bankruptcy. Mother testified at trial that her housing problems were caused by her former spouse putting his housing and utilities under her name. However, Mother also admitted that she did not pay rent for the apartment. This admission was supported by a consent judgment for rent and possession entered in October 2024 that returned possession of the apartment to the owner and found that Mother owed $8,731.60, which included $6,434.50 in rent. Dotson testified that following the entry of the consent judgment, Mother continued to live in the apartment in violation of the eviction. Dotson testified that Mother eventually moved in with her adult daughter, and that she claimed she would move into her own place shortly. Dotson testified that Mother never moved out of her adult daughter's home, and that Mother failed to provide court-ordered proof of being on the lease in a timely manner. When she eventually submitted a copy of the lease to Dotson, Mother was listed as an occupant rather than a lessee, though Mother testified that the lease was inaccurate and that she was in fact a lessee.

Concerning the trial court's order to obtain and maintain verifiable employment, the evidence established that Mother had claimed to have several jobs during the pendency of the case, but that she had failed to submit verifiable proof of these jobs. Dotson testified that Mother did not provide a requested 1099 form to prove employment at UPS. Dotson testified that Mother also failed to provide legitimate proof of working as her brother's caretaker. Dotson testified that Mother had provided a screenshot of a text addressed to her brother without any mention of Mother, a brochure from a home health program, and a chart to track vitals. When Dotson asked Mother for verifiable proof of employment as a caregiver, Mother told Dotson to call the doctor named on one of the documents to confirm that Mother was her brother's caregiver. But the doctor's name was illegible, and Mother could not provide Dotson with the doctor's name or contact information. In addition, Sears testified that she had asked Mother to provide verifiable proof of employment from March through July 2025. Sears testified that Mother did not provide any documentation, except for a screenshot of earnings from DoorDash in July 2025.

Related to the trial court's order to submit to all drug tests, Greco's testimony established that Mother either submitted to the drug tests outside of the court-ordered timeframe or did not submit to the tests at all. Greco testified that she had provided a court-ordered voucher for Mother to complete court-ordered drug tests in July 2024, January 2025, February 2025, and July 2025. Greco testified that Mother did not complete the July 2024 test in a timely manner, waiting until August 2024 to submit to the test. Greco testified that Mother never submitted to the tests in January, February, and July 2025. Greco testified that Mother offered several excuses for being unable to submit to these tests. Mother claimed that she could not submit to a requested nail test because she had acrylic nails and the facility had refused to use her toenails for the test. Greco testified that the facility's website stated that it could use fingernails or toenails for nail drug testing. Mother also claimed that the facility did not have any pending vouchers for her. Greco testified that she had called the facility and confirmed that there were vouchers waiting for Mother's use.

Greco testified that she also requested Mother to submit to seven urinalysis tests from August to November 2024. Mother submitted to only two of the seven requested tests. Greco testified that Mother later asked if she could use the results of drug tests that she had taken while on probation in lieu of submitting to the court-ordered tests. Greco testified that she had agreed as long as Mother submitted the test results. Greco testified that when she received the records of the drug tests from the probation office, the records only included the results from the two completed drug tests of the seven tests that Greco had ordered from August to November 2024. The probation office's records included no additional tests, despite Mother's claim that she had been submitting to many tests for her probation officer.

Concerning the trial court's order to install a drug patch, Dotson and Sears testified that Mother never installed the drug patch. Mother offered both caseworkers many excuses for not being able to wear the patch. Dotson testified that Mother had told him that she needed to consult with her doctor before installing the drug patch because she was concerned that the patch would “mess up her glucose or do something to her blood.” Dotson never received any documentation from a doctor to prove that Mother could not install the drug patch. Sears testified that Mother had refused to install the drug patch, claiming that her doctor had told her that she could get a false positive on the drug patch from walking by people who smoked marijuana. Sears testified that after she informed Mother that marijuana was legal in Missouri, Mother had responded that she did not want to test positive for anything. Sears testified that when she later followed up about the drug patch, Mother had again refused to install the patch, asserting that her gluten allergy could cause false positives.

Regarding the trial court's order to complete a psychological evaluation, Mother did so on August 9, 2024. Dr. Amy Barnes (“Dr. Barnes”), the clinical psychologist who completed the evaluation, testified that during the evaluation, Mother was asked to fill out a social history questionnaire, an IQ training test, two parenting assessments to evaluate risk, a substance abuse assessment, a history of childhood adverse experiences, and checklists regarding depression, trauma, and anxiety. Mother refused to complete the IQ training test. Mother also had an elevated score in lying in the “fake good” column on one of the parenting assessments. Dr. Barnes testified that this result indicated that Mother had attempted to choose all the answers that would paint her in a more virtuous or positive light by making it seem that she did not have even normal faults, thereby rendering the assessment invalid. Dr. Barnes further testified that although Mother had denied any history of drug or alcohol abuse during the evaluation, consistent avoidance of completing requested drug tests would raise concerns about substance abuse.

Dr. Barnes testified that Mother had reported that Child's school attendance issues had stemmed from Child's “Class III nonverbal autism” diagnosis, which “ha[d] kept her from going to school or caused her to be sent home early.” Dr. Barnes testified, however, that she assessed Child following Mother's evaluation and found Child to be neither nonverbal nor autistic. Dr. Barnes diagnosed Child with attention deficit hyperactivity disorder (“ADHD”). Dr. Barnes testified that she did not recommend reunification because “it's concerning that a parent would not take accountability and instead lie about their child having a severe and persistent mental illness.”

Dr. Barnes testified that following the examination, she had recommended that Mother undergo individual therapy and parenting education for a parent of a child with a disability. Dr. Barnes explained that Child was challenging to work with due to her ADHD diagnosis. She testified that Child required “a level of parenting that requires a lot more patience and a lot more understanding and knowledge, that you can't parent them in the traditional ways ․” She stated that Mother “appeared to at least have knowledge of healthy parenting but ․ I don't know if she's capable of ․ managing [Child's] ADHD behaviors.” Dr. Barnes testified that if Mother had not engaged in or completed the recommended services, then the conditions that led to the trial court's assumption of jurisdiction would likely continue in the future, and there would be a potential risk of abuse or neglect in the future.

As to the trial court's order to follow all recommendations from the psychological evaluation, the evidence established that Mother did not complete the parenting education program or participate in individual therapy. First, regarding the parenting education program, Mother testified that she had enrolled in the program in July 2024, but exited the program early in October 2024 due to being evicted and needing to work more to pay for her stay at a hotel. Sears testified that Mother had claimed that she had tried to reengage with the parenting education program, but that a woman named Betty had told her that she needed a new referral from the Children's Division to restart the program. Amy Gorton (“Gorton”), the director of the parenting education program, testified that Mother did not need any referrals to participate in the program, as there was no application or eligibility process required for access to the program. She further testified that there was no one named Betty who worked at the program. However, Gorton verified that Mother had scheduled a reenrollment appointment shortly before trial began.

Second, regarding individual therapy, Dotson testified that although Mother had told him that she did not need individual therapy, she had later attempted to provide proof of attending therapy by sending him a screenshot of an appointment reminder for a therapy session. Sears also testified that Mother had tried to prove that she had attended therapy by providing a screenshot of a scheduled appointment with a therapist named Summer Johnson. Greco testified that to help Mother prove her attendance at therapy, Greco had provided Mother with a generic release form and shown her where to go on the therapy provider's website to release her information. Greco testified that notwithstanding this guidance, Mother had never released the information to the court. Mother testified that she had been attending therapy once a month on Saturdays. But Mother could not come up with her therapist's name and testified that she did not know how to pronounce her therapist's name, despite the screenshot indicating that her name was Summer Johnson.

Altogether, this evidence established that Mother did not make an effort to progress in complying with the vast majority of the court-ordered services and that she did not take accountability for failing to make progress in complying with them, often offering inconsistent excuses. The evidence showed that the case had stagnated due to Mother's failure to progress in nurturing the bond with Child; establishing a stable home for Child to return; proving verifiable employment to provide for Child; proving her sobriety; and participating in parenting education and engaging in individual therapy to prepare for Child's return. Each of these court orders was important to ensure that the conditions that brought Child into the trial court's jurisdiction were resolved before Child returned to Mother. Mother's failure to make progress in resolving the conditions through meaningfully engaging in the court-ordered services provided substantial evidence to support the trial court's termination of Mother's parental rights on the failure to rectify grounds.

Point Three is denied. As noted above, one statutory basis for terminating Mother's parental rights is sufficient to permit us to affirm the trial court's Judgment. See Int. of S.K.J., 730 S.W.3d at 122. We therefore do not need to address Mother's first, second, and fifth points on appeal.

Points Four and Six: Substantial evidence supported the trial court's best-interests findings

Mother's fourth and sixth points essentially assert that substantial evidence did not support the trial court's findings that it was in the best interests of Child to terminate Mother's parental rights. We do not agree.

After a trial court finds that clear, cogent, and convincing evidence supports one or more statutory grounds for termination, it must determine whether termination of parental rights is in the best interests of the child. Int. of S.K.J., 730 S.W.3d at 123; section 211.447.6. “The best-interests determination ‘is a subjective assessment based on the totality of the circumstances.’ ” Int. of S.K.J., 730 S.W.3d at 123 (quoting In re A.C.G., 499 S.W.3d at 344). In making this determination, the trial court must assess and make findings on the following factors:

(1) The emotional ties to the birth parent;

(2) The extent to which the parent has maintained regular visitation or other contact with the child;

(3) The extent of payment by the parent for the cost of care and maintenance of the child when financially able to do so including the time that the child is in the custody of the division or other child-placing agency;

(4) Whether additional services would be likely to bring about lasting parental adjustment enabling a return of the child to the parent within an ascertainable period of time;

(5) The parent's disinterest in or lack of commitment to the child;

(6) The conviction of the parent of a felony offense that the court finds is of such a nature that the child will be deprived of a stable home for a period of years; ․

(7) Deliberate acts of the parent or acts of another of which the parent knew or should have known that subjects the child to a substantial risk of physical or mental harm.

Section 211.447.7(1)-(7). “There is no number of factors that needs to be proven or negated to find that termination is appropriate.” Int. of S.K.J., 730 S.W.3d at 123 (citing Int. of A.M.W., 652 S.W.3d at 244).

Here, the trial court assessed these factors, finding that (1) Child had no emotional ties to Mother because Mother did not meaningfully engage with Child during the visits and because Child did not view Mother as her parental figure; (2) Mother had maintained weekly visits but used a tablet to engage Child with little other interaction; (3) Mother had made no contribution for the cost and care of Child despite being ordered to pay $50 per month; (4) additional services would not be likely to bring about lasting parental adjustment enabling the return of Child based on its findings regarding the three statutory bases for termination of parental rights; (5) Mother had demonstrated a disinterest in and lack of commitment to Child because she had refused to fully cooperate in court-ordered programs meant to aid reunification and because she had not meaningfully interacted with Child during visits; and (6) no evidence indicated that Mother had committed any deliberate acts that subjected Child to a substantial risk of physical or mental harm.⁵ Based on these findings, the trial court determined by a preponderance of the evidence that it was in the best interests of Child to terminate Mother's parental rights.

In developing her argument that substantial evidence did not support the trial court's findings, Mother challenges the trial court's findings as to subsection (1), Child's emotional ties to Mother; subsection (2), Mother's regular visitation with Child; subsection (3), the extent Mother paid for Child's care and maintenance; and subsection (5), Mother's disinterest in or lack of commitment to Child. She asserts that the evidence showed that Mother and Child loved each other; Mother had nurtured the bond with Child through consistent visits; and Mother had provided for Child's basic needs during visits. Mother further asserts that no evidence supported that she was disinterested in or lacked commitment to Child. Similar to the flaw of her argument in her third point on appeal, Mother does not challenge the trial court's findings with respect to subsection (4), that additional services would not be likely to bring about lasting parental adjustment enabling Child's return. As the trial court could base its best-interests finding on any number of the enumerated factors, Mother's failure to challenge all the factors that the trial court found applicable to the case is fatal to her fourth and sixth points on appeal. See Int. of S.K.J., 730 S.W.3d at 123 (“There is no number of factors that needs to be proven or negated to find that termination is appropriate.”) (citation omitted).

Nevertheless, even had Mother's challenge been sufficient, the record provides substantial evidence to support the trial court's findings as to each of the challenged factors. First, regarding subsection (1), Child's emotional ties to Mother, we agree with Mother that the evidence established that Mother and Child loved each other. Sears testified that she had observed that Child loved Mother. But Sears had also noticed that Child did not view Mother as a parental figure and that Child's focus shifted during visits from engaging with Mother to just playing on the tablet after Mother missed a visit. Additionally, Roxanna Aramjoo (“Aramjoo”), the court-appointed special advocate from June 2024 to the hearing in August 2025, testified that Child loved Mother “because it's an obligation.” Aramjoo testified that Child did not feel like Mother gave “her the things that she needs as a child.” Aramjoo testified that during visits, Child did not want to tell Mother about her activities, like swimming and soccer, because she did not want Mother to get mad at her. Aramjoo testified that Child had stated that her experience with Mother before entering into foster care had not involved “lots of care, and hugging” and that she had been scared when she was home with Mother. This testimony that Child did not view Mother as a parental figure, that Child did not like to tell Mother about her life, and that Child feared Mother provided substantial evidence to support the trial court's finding that Child had no emotional ties to Mother.

Second, regarding subsection (2), the extent to which Mother had maintained regular visitation with Child, we also agree with Mother that she went to nearly every visit with Child. Nevertheless, Dotson and Sears both testified that Mother brought a tablet to visits and that she did not otherwise engage Child. Aramjoo also testified that when she asked Child about her visits with Mother, Child had said that she did not talk with Mother during visits and that they just played on the tablet. This testimony provided substantial evidence to support the trial court's finding that although Mother had maintained consistent visits with Child, Mother had not meaningfully engaged Child during the visits.

Third, with respect to subsection (3), the extent of Mother's payment for the cost of care and maintenance of Child, we further agree that Mother provided basic needs during visits. But providing basic needs during visits is different than paying for the cost of Child's care and maintenance. Greco testified that Mother never complied with the trial court's order to pay $50 per month for Child's care and maintenance. Mother admitted at trial that she did not pay this court-ordered amount. This testimony provided substantial evidence to support that Mother had failed to pay any money for Child's care and maintenance during the pendency of the case, despite being specifically ordered to do so.

Fourth, as to subsection (5), Mother's disinterest in or lack of commitment to Child, we disagree with Mother that no evidence was presented to support this factor. Although Sears testified that Mother cared about Child, other evidence at trial established that Mother did not make an effort to fully engage with court-ordered programs that were intended to aid reunification with Child. As described at length in our discussion of the third point on appeal, the evidence established that Mother had failed to pay $50 per month for Child's care and maintenance; to establish safe, stable housing for Child's return; to obtain verifiable employment to provide for Child; to prove sobriety through submitting to all requested drug tests; and to follow Dr. Barnes's recommendations to complete parenting education and participate in individual therapy. Additionally, the evidence established that despite Mother's attendance at nearly every visit, she did not meaningfully engage Child during the visits. Dotson and Sears testified that Mother brought a tablet for Child to play with during visits, and Aramjoo testified that Child had affirmed that she and Mother only watched movies on the tablet without otherwise talking during the visits. The totality of these circumstances provided substantial evidence to support the trial court's determination that Mother showed a disinterest in or lack of commitment to Child through failing to make progress in complying with court orders meant to aid reunification and to meaningfully engage with Child during her weekly visits.

In light of the substantial evidence supporting each of the challenged best-interests factors, the record does not support a conclusion that the trial court abused its discretion in finding that it was in the best interests of Child to terminate Mother's parental rights. See Int. of S.K.J., 730 S.W.3d at 117 (“An abuse of discretion occurs only when the trial court's ruling is clearly against the logic of the circumstances and [is] so unreasonable and arbitrary that it shocks the sense of justice and indicates a lack of careful, deliberate consideration.”) (quotation omitted).

Points Four and Six are denied.

Conclusion

The Judgment is affirmed.

FOOTNOTES

1.   Child's biological father is also R.P. (“Father”). Child's parents have the same initials and are thus referred to as Mother and Father for clarity.The trial court also terminated Father's parental rights following Father's written consent. Father is not a party to this appeal.

3.   References to sections 211.031 and 211.183 are to RSMo 2016 as supplemented to April 11, 2024, the date that Child became a ward of the court. All other statutory references are to RSMo 2016 as supplemented to September 22, 2025, the date Mother's parental rights were terminated as to Child, unless otherwise indicated.

4.   Mother's points on appeal do not assert an against-the-weight-of-the evidence argument, given that “[a] claim that the judgment is against the weight of the evidence presupposes that there is sufficient evidence to support the judgment,” and that all of the points contend that the evidence was insufficient to support each of the challenged findings. S.S.S. v. C.V.S., 529 S.W.3d 811, 815 (Mo. banc 2017) (quoting Ivie v. Smith, 439 S.W.3d 189, 205 (Mo. banc 2014)).

5.   Although the trial court was required to make findings on each subsection, the trial court did not make a finding as to subsection (6), regarding whether Mother had a felony. Mother does not challenge the trial court's failure to do so. Even if she had, the issue would not be preserved for appeal. Rule 78.07(c) requires the failure to make statutorily required findings to be raised in a motion to amend the judgment in order to be preserved for appellate review. Mother did not file any post-trial motions in this case and did not therefore preserve any argument related to the trial court's failure to make all statutorily required findings. In any event, the record does not disclose any evidence to support that Mother had a felony, the subject of subsection (6).

Cynthia L. Martin, Judge

All concur