Missouri Court of Appeals, Southern District / Feb 4, 2020
IN THE INTEREST OF: A.R.F. GREENE COUNTY JUVENILE OFFICE, Respondent vs. V.H.F., Appellant
V.H.F. (Mother) appealed the trial court's judgment terminating her parental rights to A.R.F. (Child) on multiple statutory grounds, including neglect and parental unfitness. Mother argued the trial court erroneously applied the law by failing to conduct a separate, explicit prospective analysis of the likelihood of future harm, relying only on past acts. The appellate court affirmed the judgment, holding that Mother misconstrued the relevant precedent, and the future harm analysis is an integral part of determining termination grounds and best interest, not a stand-alone element.