Reasonable reunification efforts; Failure to adjourn the termination hearing

Holding that there were no errors warranting reversal, the court affirmed termination of respondent-mother’s parental rights to the children. Respondent first argued that DHHS “did not satisfy its statutory obligation to provide reasonable services toward reunification.” Specifically, she argued that DHHS “failed to provide her with mental health services to assist her in overcoming her dependency on controlled substances.” The court held that the record did not support her assertion that DHHS “failed to make reasonable efforts to reunite respondent with her children. And, considering respondent’s failure to participate in and benefit from the services provided, respondent has not demonstrated that she would have fared better if additional services had been offered.” Thus, she was not entitled to relief as to this issue. Respondent next argued that “the trial court erred by failing to adjourn the termination hearing on [1/6/22], after becoming aware that she had recently used drugs and may be experiencing withdrawal symptoms.” The court held that under “the circumstances, considering the trial court’s efforts to investigate the situation, and that respondent was represented by a lawyer, repeatedly denied that she was under the influence of any substances, and stated that she could proceed, the trial court did not violate respondent’s right to due process by continuing the hearing.” Moreover, respondent did “not explain how her condition affected the proceedings, or how the proceedings would have been different if the court had continued the hearing to another date.” Thus, she failed to show that she was entitled to relief on the basis of this issue.