In re Kaliyah S.
Annotate this CaseIn 2011, the Department of Children's Services (DCS) filed a petition to terminate Father’s parental rights to his child. In 2013, the juvenile court terminated the parental rights of Father. The court of appeals reversed, holding that DCS was required to make reasonable efforts to assist Father, and reasonable efforts were not made. At issue was whether, in a petition to terminate the parental rights of a biological parent, the State is required to prove that it made reasonable efforts to reunify the parent with the child as a precondition to termination. The Supreme Court reversed the court of appeals in this case, holding that, pursuant to Tenn. Code Ann. 36-1-113, the State need not prove that it made reasonable efforts as an essential component of its petition to terminate parental rights. In so holding, the Court overruled In re C.M.M. and its progeny to the extent the cases required the State to prove reasonable efforts as an essential component of the termination petition.
Court Description: Authoring Judge: Justice Holly Kirby
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.