State of Florida, Department of etc. v. T. S., the Father and A. B., the Mother

The trial court found that the Department of Children and Families established the statutory factors for termination of parental rights and that termination was in the manifest best interests of the child. These findings are not disputed on appeal, and would ordinarily support á termination order. The trial court, however, concluded that termination was not the least restrictive means to protect the child from harm, a ruling the Department now appeals. We agree with the Department that the trial court improperly relied on “the availability of a nonadoptive placement with a relative” when…