RN v. State
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The Supreme Court reversed the judgment of the juvenile court changing the permanency plan in this case to adoption, holding that remand was required because the juvenile court failed to make the required reasonable efforts determination.
In 2021, Child was taken into protective custody. The Department of Family Services (DFS) subsequently implemented a case plan for Mother and Child with the goal of family reunification. Eighteen months later, the court changed the permanency plan to adoption because Mother had made little to no progress on the plan. The order, however, contained no findings regarding DFS's reasonable efforts to reunite Mother and Child. The Supreme Court reversed, holding that because the juvenile court's written order was devoid of the required reasonable efforts determination remand was required for the juvenile court to make that determination.
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