In Re The Dependency Of M.r.d., Leanna Hanson, V. Dcyf, 82195-4

M.R.D. was removed at birth after testing positive for opiates; mother Leanna Hanson admitted using heroin and methamphetamine during pregnancy and a dependency was entered.
The dispositional order required frequent urinalysis, a drug/alcohol evaluation and treatment, a parenting assessment (with a mutually agreed provider), and supervised visitation (twice weekly, two hours).
Hanson largely did not engage: she missed multiple hearings, rarely visited (at most ~10 times in two years), and did not complete court-ordered services.
DCYF social workers attempted repeated contacts, sent service-letter packets to Hanson’s last known address and to her parents (where Hanson occasionally collected mail), and spoke with Hanson once in the hospital in August 2020; Hanson declined aid and said she would work through her attorney.
The trial court found DCYF had expressly and understandably offered all ordered and necessary services, that Hanson’s untreated substance abuse made reunification unlikely in the foreseeable future, and it terminated Hanson’s parental rights; Hanson appealed.

Issue	Plaintiff's Argument (Hanson)	Defendant's Argument (Department)	Held
Whether DCYF "expressly and understandably offered" all court-ordered and necessary services under RCW 13.34.180(1)(d)	DCYF did not prove Hanson actually received service letters; no referral was made for a parenting assessment; DCYF effectively conditioned services on prerequisites Hanson did not meet.	DCYF made reasonable efforts: multiple contact attempts, letters left at last known addresses and grandparents, direct hospital contact where services/offers were explained; the dispositional order required mutual selection of parenting-assessment provider, so referral procedure was lawful; parenting assessment also would not cure Hanson’s primary deficiency (substance abuse) in the foreseeable future.	Affirmed. Substantial evidence supported that services were expressly and understandably offered/provided; parenting-assessment procedures were proper; termination was appropriate given Hanson’s untreated substance abuse and low likelihood of reunification within the child’s foreseeable timeframe.

In re Welfare of A.B., 168 Wn.2d 908 (2010) (describes two-step burden in termination proceedings under RCW 13.34.180)
In re Parental Rights to K.M.M., 186 Wn.2d 466 (2016) (defines "necessary services" for reunification)
In re Dependency of K.R., 128 Wn.2d 129 (1995) (standard for clear, cogent, and convincing evidence)
In re Parental Rights to D.H., 195 Wn.2d 710 (2020) (appellate review principles in termination cases)
In re Dependency of A.M.M., 182 Wn. App. 776 (2014) (services needed to address conditions preventing reunification)
In the Matter of D.J.S., 12 Wn. App. 2d 1 (2020) (holding that DCYF cannot withhold ordered services by imposing unauthorized prerequisites)
In re Dep. of T.R., 108 Wn. App. 149 (2001) (service necessity evaluated against whether it would remedy parental deficiencies in the foreseeable future)
In re Welfare of Hall, 99 Wn.2d 842 (1983) (deference to trial court in fact-intensive termination proceedings)