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After the trial court has found a statutory ground for terminating a parent’s rights, it must consider whether terminating the parent’s rights, or some alternative dispositional order, is in the child’s best interest.

Analysis When reviewing an appeal of termination of parental rights, we will not disturb the trial court’s findings unless they are unsupported by the evidence or plainly erroneous as a matter of law.

II In reviewing an appeal of termination of parental rights (TPR), we will not disturb the trial court’s findings unless they are unsupported by the evidence or plainly erroneous as a matter of law.

We will not disturb the trial court’s findings unless they are unsupported by the evidence or plainly erroneous as a matter of law.

We will not disturb the circuit court’s finding unless it is unsupported by the evidence or plainly erroneous as a matter of law.

These findings are supported by the extensive record before us. See, e.g., In re Zachary G., 159 N.H. 146, 153 (2009) (family division’s findings will not be disturbed unless unsupported by the evidence or plainly erroneous as a matter of law).

See, e.g., In re Zachary G., 159 N.H. 146, 152 (2009) (declining, in light of the potential adverse impact on the public interest, to apply collateral estoppel in termination of parental rights proceeding); State v. Cassady, 140 N.H. 46, 49 (1995) (declining to give collateral estoppel effect to findings of administrative license suspension hearing in subsequ

The trial court’s ruling should not be disturbed unless it is unsupported by the evidence or plainly erroneous as a matter of law.

4 If the circuit court finds a statutory ground for terminating a parent’s rights, it must then consider whether terminating the parent’s rights is in the child’s best interests.

see In re Zachary G., 159 N.H. 146, 152 (2009) (recognizing that judicial estoppel “protects judicial integrity by preventing a party from prevailing in one phase of a case using one argument and then relying upon a contradictory argument to prevail in another phase” (quotation and brackets omitted)).

“After the court finds statutory grounds for termination, it must further consider whether termination is in the [child’s] best interest.” In re Zachary G., 159 N.H. 146, 157 (2009).

these statements in the jointly filed ITS amount to admissions by the State that Willey is a professional gambler and that this fact is not in dispute.7 “The doctrine of judicial estoppel protects judicial integrity by preventing a party from prevailing in one phase of a case using one argument and then relying upon a contradictory argument to prevail in another phase.” In re Zachary G., 159 N.H. 146, 152 (2009) (quotation omitted).

Thus, in order to rely upon RSA 170-C:5, III as grounds for termination, DCYF must demonstrate: (1) a finding of child neglect or abuse under RSA chapter 169-C; (2) a failure to correct the same within twelve months of the finding; and (3) reasonable efforts under the direction of the court to rectify the conditions.

Id.; see In re Zachary G., 159 N.H. 146, 153 (2009) (family division); RSA 170-C:5; see also RSA 490-D:14 (2010) (statutory references to probate courts include the judicial branch family division).

McNair v. McNair, 151 N.H. 343, 354 (2004); In re Zachary G., 159 N.H. 146, 151 (2009).