In re S.T..., 521 P.3d 887

Mother has three children (J.P., S.T., Z.T.); she and the children’s fathers had histories of meth use and domestic violence.
DCFS opened a protective-supervision case in 2019 after a domestic-violence incident; an in‑home service plan was adopted and repeatedly found reasonable by the juvenile court.
In Feb 2020 Mother was arrested for DUI with the children in the vehicle; the children were removed and placed in DCFS custody.
DCFS and Mother created a March 2020 reunification Plan requiring sobriety, random drug testing, substance‑abuse and mental‑health assessment/treatment, parenting classes, stable housing, and regular contact with DCFS; DCFS provided services through Feb 2021.
Mother was repeatedly noncompliant (continued drug use, sporadic testing and therapy, arrests, unstable housing, ongoing contact with Father); parent‑time reportedly produced negative behavioral effects in the children.
In Feb 2021 reunification services were terminated and the permanency goal changed to adoption; after a two‑day termination trial the juvenile court found statutory grounds and that termination was in the children’s best interest and strictly necessary to permit adoption by the foster parents. The court’s termination order is affirmed on appeal.

Issue	Mother’s Argument	State’s Argument	Held
Whether DCFS made reasonable efforts to reunify	DCFS failed to provide needed domestic‑violence services and adequate mental‑health services (timely bipolar II diagnosis)	DCFS reasonably provided services (including domestic‑violence help); Mother helped draft the Plan but did not consistently participate in therapy, testing, or other requirements	No plain error; juvenile court’s findings that reasonable efforts were made are affirmed
Whether termination was in the children’s best interest / strictly necessary	Court’s best‑interest analysis was conclusory and failed to meaningfully consider alternatives to termination (e.g., guardianship)	Court evaluated statutory factors, found children had strong attachments to foster parents, had thrived in foster home, and that alternatives were infeasible; termination was strictly necessary to secure permanency via adoption	Court did not abuse discretion; best‑interest and strictly‑necessary findings are supported and affirmed

In re J.A.L., 2022 UT 12, 506 P.3d 606 (articulates best‑interest and "strictly necessary" analysis and addresses plain‑error review issues)
In re J.M., 2020 UT App 52, 463 P.3d 66 (discusses standard of review and fact‑factual recitation in termination appeals)
In re N.K., 2020 UT App 26, 461 P.3d 1116 (reasonable‑efforts requirement and preservation principles)
In re K.F., 2009 UT 4, 201 P.3d 985 (defines reasonable‑efforts as a fair and serious attempt)
In re A.W., 2018 UT App 217, 437 P.3d 640 (reasonableness is fact‑intensive; parents must challenge interim findings before termination)
In re B.T.B., 2020 UT 60, 472 P.3d 827 (explains the court’s duty to explore feasible alternatives before concluding termination is strictly necessary)
In re A.H., 2021 UT App 57, 493 P.3d 81 (reunification is a two‑way street; parents must participate in services)
Cove at Little Valley Homeowners Ass’n v. Traverse Ridge Special Serv. Dist., 2022 UT 23, 513 P.3d 658 (discusses applicability of plain‑error review in civil contexts)
Kelly v. Timber Lakes Prop. Owners Ass’n, 2022 UT App 23, 507 P.3d 357 (addresses limits of plain‑error doctrine in civil appeals)