In re N.B.
Annotate this Case
The case involves the Department of Children, Youth, and Families (DCYF) in Rhode Island, which was held in contempt by the Family Court for failing to place a minor, N.B., in a specific facility, St. Mary’s Home for Children, as ordered by the court. N.B., who has behavioral issues and Type I juvenile diabetes, was initially placed in Hasbro Children’s Hospital after her mother refused to take her home due to safety concerns. The Family Court ordered DCYF to place N.B. at St. Mary’s, but the facility refused to admit her due to her medical needs and behavioral issues. Despite DCYF's efforts to secure a placement for N.B., including contacting multiple potential placements and attempting to hire nurses to monitor N.B.'s diabetic care needs, no suitable placement was available.
The Family Court found DCYF in contempt for failing to place N.B. at St. Mary’s, rejecting DCYF's argument that it was impossible to comply with the placement order. The court ordered DCYF to pay a daily sanction until it complied with the order. DCYF appealed the contempt order, arguing that the Family Court abused its discretion by finding that DCYF had not exercised reasonable efforts to place N.B. and that it was impossible to comply with the placement order.
The Supreme Court of Rhode Island vacated the Family Court’s contempt order. The Supreme Court found that DCYF had made substantial efforts to place N.B. at St. Mary’s and other appropriate facilities, but compliance with the placement order was outside the department’s control due to circumstances such as the refusal of facilities to accept N.B. and ongoing nursing shortages related to the COVID-19 pandemic. The Supreme Court concluded that the Family Court had abused its discretion in finding that DCYF had not used reasonable efforts to place N.B. and in holding DCYF in contempt.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.