In re N.K., 461 P.3d 1116

In Nov. 2017 DCFS removed N.K. (age 2) after Mother’s arrest and placed the child with a relative foster family; Father lived in California and had not seen the child for about six months prior to removal.
DCFS implemented a reunification plan requiring Father to complete domestic-violence, mental-health, and substance assessments, random drug testing, parenting classes, obtain stable housing/income, and maintain contact with Child.
Father delayed or failed to complete many tasks, participated in few in-person visits (one in-person visit ended early), relied on sporadic video calls, and did not engage in Child’s therapy or services.
DCFS terminated reunification services in Oct. 2018 and sought termination of Father’s parental rights; the juvenile court found multiple statutory grounds (neglect, failure of parental adjustment, token efforts, etc.), that DCFS made reasonable efforts, and that termination was strictly necessary for Child’s best interests.
Father appealed challenging (1) the sufficiency of evidence for neglect/unfitness, (2) the finding that DCFS made reasonable efforts, and (3) whether termination was strictly necessary; the Court of Appeals affirmed.

Issue	Plaintiff's Argument (Father)	Defendant's Argument (State/DCFS)	Held
Whether DCFS made reasonable efforts to reunify	DCFS efforts were inadequate given out-of-state barriers, inability to pay for travel/services, and flawed assessments	DCFS made multiple contacts, arranged services, researched options, offered financial help (hotel), scheduled visits, and coordinated with CA services	Affirmed: court properly found DCFS made reasonable efforts; Father failed to show insufficient efforts or preserve objection
Whether termination was strictly necessary for Child’s best interests	Court failed to explore/consider alternatives; termination not strictly necessary	Father had no established bond, failed to address Child’s special needs; foster family formed secure attachment, improved Child’s functioning, and is willing to adopt	Affirmed: termination strictly necessary given the totality of circumstances and lack of feasible alternatives
Sufficiency of evidence for neglect and unfitness	Insufficient proof that Father was neglectful or unfit	Multiple statutory grounds established (token efforts; failure to remedy; neglect/failure of parental adjustment); court may terminate on any ground supported by evidence	Court did not resolve Father’s challenge to those two grounds because other uncontested grounds supported termination; overall termination affirmed

In re B.T.B., 436 P.3d 206 (Utah Ct. App. 2018) (standards for termination review and best-interests deference)
In re M.C., 82 P.3d 1159 (Utah Ct. App. 2003) (mixed question review of reasonable-efforts finding)
In re C.T., 438 P.3d 100 (Utah Ct. App. 2018) (requirement to consider alternatives to termination)
In re M.W., 12 P.3d 80 (Utah 2000) (preservation requirement for reasonable-efforts claims)
In re A.W., 437 P.3d 640 (Utah Ct. App. 2018) (parent bears burden to show DCFS failed reasonable-efforts)
Howick v. Salt Lake City Corp., 424 P.3d 841 (Utah 2018) (appellate review limitation when alternative grounds remain)
In re C.R.C., 450 P.3d 1169 (Utah Ct. App. 2019) (deference to juvenile court termination decisions)