In Re: I.E.A., et al.

The case involves the termination of Mother‘s parental rights on the ground of severe abuse. The trial court terminated Mother‘s parental rights to the two children at issue based on two previous severe abuse findings against Mother: (1) a finding as to the children at issue during the dependency and neglect portion of the underlying proceedings; and (2) a finding that the children‘s older half-sibling was the victim of severe abuse prior to the children at issue‘s birth. The trial court further found clear and convincing evidence that termination was in the children‘s best interest. Although we conclude that the trial court erred in relying on a non-final order as res judicata of the ground of severe abuse, we find that the trial court did not err in relying on a prior final order of severe abuse as to the children at issue‘s half-sibling. We also affirm the trial court‘s finding that termination of Mother‘s parental rights is in the children‘s best interests.