In re C.E., 172 A.3d 476

C.D., mother of infant C.E., has a long history of mental illness and prior juvenile-court proceedings; four of her six children previously had parental rights involuntarily terminated after contested hearings.
C.E. was removed shortly after birth and adjudicated a Child in Need of Assistance (CINA); C.E. was placed with relatives and the permanency plan favored relative placement.
The Department filed a motion under CJP § 3-812 to waive its statutory obligation to provide continued reasonable reunification efforts, citing C.D.’s involuntary loss of parental rights to multiple siblings.
The juvenile court granted the Department’s motion, concluding the statutory ground (prior involuntary terminations) was met and waiving reunification services; C.D. immediately appealed that interlocutory waiver order.
The Court of Special Appeals held the waiver order was not immediately appealable as a final or qualifying interlocutory order under CJP § 12-303(3)(x) and affirmed; one intermediate-court decision had previously held such waivers appealable, creating a conflict.
The Court of Appeals granted certiorari to resolve whether an order waiving reasonable reunification efforts is immediately appealable and declined to address C.D.’s constitutional challenges to § 3-812.

Issue	Plaintiff's Argument (C.D.)	Defendant's Argument (Department)	Held
Whether an interlocutory juvenile-court order waiving the Department’s obligation to provide reasonable reunification efforts is immediately appealable under CJP § 12-303(3)(x)	The waiver effectively deprives C.D. of the care or custody of C.E. and changes the terms affecting her fundamental parental rights, creating a statutory right to immediate appeal	The waiver did not alter custody or the permanency plan; it only relieved the Department of providing services and is therefore not an appealable interlocutory order	Held: Not appealable under § 12-303(3)(x); waiver left custody and permanency plan unchanged and did not deprive parent of care or custody
Whether CJP § 3-812 is facially or as-applied unconstitutional (substantive due process, procedural due process, equal protection)	§ 3-812 penalizes parents who contested prior terminations and forecloses reunification rights, violating constitutional protections	(Not reached on appeal)	Court declined to reach constitutional challenges; reserved for another day

In re Karl H., 394 Md. 402 (discussion of when interlocutory orders change antecedent custody orders and are appealable)
In re Joseph N., 407 Md. 278 (non-final order transferring immediate custody was appealable due to meaningful shift in reunification prospects)
In re Samone H., 385 Md. 282 (denial of a beneficial service that left permanency plan unchanged was not appealable)
In re Billy W., 386 Md. 675 (authoritative treatment of appealability of juvenile-court interlocutory orders)
In re Damon M., 362 Md. 429 (appealability in permanency-plan context)
Peat v. Los Angeles Rams, 284 Md. 86 (definition and characteristics of an appealable final judgment)
Rohrbeck v. Rohrbeck, 318 Md. 28 (three attributes of a final judgment)
In re Ashley S., 431 Md. 678 (CINA statutory purposes: timely permanent placement)
Kurstin v. Bromberg Rosenthal, LLP, 420 Md. 466 (noting appeal is a legislative grant; limits on appellate jurisdiction)