In re G.F.
Annotate this CaseFather appealed a circuit court order terminating his parental rights over his minor child, G.F., on the ground that he failed to correct, within twelve months, the conditions that led to the court’s finding under RSA chapter 169-C (2022) that G.F. was neglected by G.F.’s mother. In January 2020, father did not attend mother’s adjudicatory or dispositional hearings. Mother entered into a consent agreement acknowledging that neglect occurred due to her drug use. At the dispositional hearing, the circuit court adopted a case plan and dispositional orders, which also applied to father. Father was not served with these documents. At the three-month review hearing, father's counsel received the case plan, dispositional orders and related discovery. Two days after the six-month review hearing, father was arrested for felony second degree assault and other domestic violence charges involving his then girlfriend and her minor child. He pled guilty to at least two of the charges. In September 2020, a nine-month review hearing was held. In January 2021, the trial court held the first permanency hearing in the neglect case while father was incarcerated. The trial court found father was not in compliance with dispositional orders. The trial court changed the permanency plan from reunification to adoption and specified that “DCYF is no longer required to provide reasonable efforts to facilitate reunification between [G.F.] and mother [and] father, but shall make reasonable efforts to finalize the permanency plan.” In September 2021, the circuit court held a second permanency hearing; again the court found father was not in compliance with the dispositional orders and concluded G.F. could not be safely returned to his care. DCYF filed a new petition to terminate the father’s parental rights in October 2021. In December 2021, the father was released from incarceration. In February 2022, the circuit court granted DCYF’s petition to terminate the father’s parental rights. Assuming without deciding that, during the nine months in which DCYF was ordered by the court to make reasonable efforts to reunify G.F. with his father, those efforts were reasonable, the New Hampshire Supreme Court concluded that DCYF failed to meet its burden because the court did not order DCYF to make such efforts for the remaining three months. Accordingly, the Supreme Court reversed the trial court’s order terminating the father’s parental rights over G.F.
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