Dept. of Human Services v. T.S.

To determine whether Department of Human Services (DHS) established reasonable efforts to reunify both the mother and the father, the efforts should be viewed through the totality of the case. DHS needs to endeavor to reunify both parents, even if it appears that only one will eventually be reunified.

Father appealed the permanency hearing judgment that changed his daughter's (T) plan from reunification to adoption, alleging that the juvenile court erred in determining that the Department of Human Services (DHS) had made reasonable efforts to reunify T with the father. The father has been in and out of jail since T was born four years ago. In the beginning, both he and DHS made an effort for him to get into a rehabilitation program, take parenting and anger control classes, and to establish a relationship with T. However, when the father was incarcerated in middle of 2012, DHS did not make further effort to assist the father despite his numerous attempts to contact DHS and ask for assistance. The father, on his own initiative, took what action he could to make substantial changes in his life and attempted to establish a relationship with T. DHS finally made contact with father in September of 2013 but only after T was removed from her mother's custody. This Court found that when looking at the case in its totality, DHS did not provide reasonable effort to reunify the father with T. Reversed and Remanded.