Adoption/Guardianship: Termination of parental rights: Mental health issues CSA No. 1798, September Term, 2012, Unreported. Opinion by Nazarian, J. Filed March 8, 2013. 16 pages. Appeal from Montgomery County Circuit Court. Affirmed.

A trust in favor of a mentally impaired 19-year-old cannot be considered a “means of subsistence” under the destitute adult child statute, as long as she has no access to the funds, the Court of Special Appeals has held.

CSA No. 406, September Term, 2012. Unreported. Opinion by Berger, J. Filed November 29, 2012. 30 pages. Appeal from Howard County. Affirmed. Custody and visitation: Mental health issues: Limited access

CINA: Risk of future abuse or neglect: Mental health issues of parent CSA No. 0129, Sept. Term 2012. Unreported. Opinion by Zarnoch, J. Filed Sept. 25, 2012. RecordFax #12-0925-00, 18 pp.