In re B.H. (Signed Opinion)
Annotate this CaseThe circuit court adjudicated Mother’s two children abused and neglected and awarded Mother a six-month post-adjudicatory improvement period. After the conclusion of Mother’s improvement period, the circuit court granted primary custodial responsibility to the children’s father (Father) and granted Mother unsupervised visitation with the children. The Supreme Court affirmed, holding that the circuit court did not err by granting Father primary custody of the children where (1) Mother had substantially complied with the terms and conditions of her improvement period because, in making the final disposition in a child abuse and neglect proceeding, the level of a parent’s compliance with the terms and conditions of an improvement period is just one factor to be considered; and (2) any delay in awarding unsupervised visitation to permit Mother to demonstrate what she had learned from her improvement period was due to Mother’s own actions, which caused continuing concern for the children’s safety.
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