In Re The Dependency Of Enm, Bertram Mackey v. Dshs, 75178-6

Child E.M. (b. Jan. 23, 2014) lived in licensed foster care since birth; parents Bertram Mackey and Andrea Thompson were homeless and engaged.
Thompson was found incompetent due to severe mental illness; her parental rights were terminated in separate proceedings.
Mackey has amnesia for events before Oct. 2012 and underwent neuropsychological and psychological evaluations; Dr. Harmon diagnosed conversion disorder and suspected paranoid personality disorder, expressing concern about Mackey's lack of insight.
The dispositional plan required a neuropsychological evaluation and supervised visits; the Department arranged services through Community Psychiatric Clinic (CPC) after initial provider refusals.
At CPC Mackey received therapy from a master’s-level clinician (Britt Alvy) and a psychiatric evaluation by Dr. Sylvester, who diagnosed dissociative amnesia and recommended continued therapy but no medication; Mackey attended nine sessions by trial.
The trial court found the Department had offered all reasonably available services capable of correcting Mackey’s parental deficiencies and terminated his parental rights; Mackey appealed only the RCW 13.34.180(1)(d) services issue.

Issue	Plaintiff's Argument (Mackey)	Defendant's Argument (Department)	Held
Whether the Department offered or provided all reasonably available services capable of correcting parental deficiencies (RCW 13.34.180(1)(d))	Services were inadequate because treatment was provided by a master’s-level therapist at CPC rather than a psychiatrist or higher-qualified provider; a more qualified provider would likely have produced insight and corrected deficiencies	CPC treatment (therapy plus psychiatric evaluation) was appropriate and as effective as reasonably possible; Mackey refused to acknowledge problems, limiting prognosis and utility of further services	Affirmed: substantial evidence supports finding that Department offered/provided all necessary, reasonably available services capable of correcting deficiencies within foreseeable future

Santosky v. Kramer, 455 U.S. 745 (procedural due process standard for parental rights termination)
In re Welfare of A.B., 168 Wn.2d 908 (Washington standard for termination of parental rights)
In re Welfare of A.W., 182 Wn.2d 689 (deference to trial court credibility findings in parental-rights cases)
State v. Camarillo, 115 Wn.2d 60 (appellate deference to factual findings)
In re Dependency of K.R., 128 Wn.2d 129 (clear, cogent, and convincing evidence standard in dependency proceedings)