In re K.A.W.
Supreme Court of Missouri
133 S.W.3d 1 (2004)
T.W. (defendant), already raising three children while working full time, decided that another family could better provide for her infant twins and pursued an adoption, ultimately having the twins adopted by a British family in Arkansas (a state permitting open adoption, unlike Missouri) after falsely claiming Arkansas residency; when the British family was later found unfit and the Arkansas adoption was set aside for lack of jurisdiction, T.W. decided to forgo adoption and raise the twins herself, fully complying with a comprehensive parenting plan involving classes, visitation, financial support, and drug screenings while the twins remained in state custody. The trial court nonetheless terminated T.W.'s parental rights based on a pattern of living instability, temporary placement, and indecisiveness, and T.W. appealed.
Whether a parent's past instability and indecisive decision-making during a failed adoption attempt may support terminating her parental rights, when she has since fully complied with a comprehensive parenting plan indicating her ability to care for the children going forward.