Termination under § 19b(3)(c)(i); In re Williams; Reasonable reunification efforts

Holding that the trial court did not err in (1) finding that the DHHS made reasonable reunification efforts or (2) terminating respondent-mother’s parental rights under § (c)(i), the court affirmed. As to her unpreserved claim related to reunification efforts, respondent alleged that it was “‘unclear’ what, ‘if any,’ services DHHS provided to assist her with housing, employment, or transportation, but” she failed to “actually allege no services were offered or explain how, if they were, the offered services were deficient.” She further contended that it “failed to locate, or pay for, her substance abuse treatment. However, the record reflects that respondent was referred to substance-abuse treatment, but failed to uphold her ‘commensurate responsibility’ to engage in and benefit from it.” Her assertion that the “DHHS should have found, and paid for, treatments that did not require Medicaid because she failed to apply for it until late in the proceedings also” lacked merit. The “DHHS is required to make reasonable efforts—not limitless or excessive ones.” Further, the record showed it made several “attempts to work with respondent to help her apply for Medicaid so that she could pursue more services, but [she] nonetheless failed to do so.” As to § (c)(i), over 182 days had passed since the initial disposition. The children were removed “because of improper care and supervision, substance abuse, and untreated mental health issues. Respondent was referred to numerous services throughout the lengthy lower court proceedings to address these issues, but failed to timely participate in, or benefit from, them. As a result, [she] failed to address her mental health and substance abuse issues. When DHHS ultimately petitioned” to terminate her parental rights, she “had missed 59 of the 69 substance screenings she was offered. Seven of the tests [she] did complete were positive for illegal substances.” In addition, she “failed to address her issues with parenting skills[,]” stopped attending parenting time visits, and “still lacked stable housing.”