In Re The Dependency Of H.l.h., 81890-2

H.L.H. (b. 2012) was made dependent in May 2016 after the mother’s November 2015 arrest for felony assault while possessing controlled substances and an incident where a man refused to release the child to police.
The dispositional order required weekly random urinalysis (90 days) and completion of a parenting assessment and its recommendations; domestic violence support group was recommended but not mandatory.
The Department assigned social workers who provided multiple service letters, referrals (mental-health providers, parenting coaching, Triple P), and updated the list after the parenting assessment.
The mother completed the parenting assessment but largely failed to complete or consistently engage in court-ordered services (urinalysis, parenting coaching, inpatient drug treatment, DV support) and had sporadic visitation and frequent incarcerations.
The Department filed to terminate parental rights in March 2019; after a vacated April 2020 judgment (mother was incarcerated and absent), a retrial was held Aug–Sep 2020. The trial court found the mother unfit due to unresolved substance abuse, mental-health issues, criminal lifestyle, and inability to separate from a violent partner, and terminated her parental rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Department "expressly and understandably" offered all necessary, reasonably available services under RCW 13.34.180(1)(d)	Mother: The parenting-assessment requirement to engage in individual therapy was vague and ill-defined, so the Dept did not "expressly and understandably" offer the therapy required by the court order.	Dept: It repeatedly communicated the parenting-assessment recommendations, sent at least eight updated service letters listing providers and contact information, and explained how to access individual therapy.	Court: Affirmed — substantial evidence shows the Dept expressly and understandably offered individual therapy and other services; M.A.S.C. is distinguishable.

Santosky v. Kramer, 455 U.S. 745 (termination of parental rights involves fundamental liberty interest)
In re Welfare of A.B., 168 Wn.2d 908 (two-step process and burden for terminating parental rights)
In re Parental Rights to K.M.M., 186 Wn.2d 466 (definition of "necessary services" and Department duties)
In re Parental Rights to D.H., 195 Wn.2d 710 (standard of review—trial court findings supported by substantial evidence)
In re Dependency of K.R., 128 Wn.2d 129 (clear, cogent, and convincing evidence standard)
In re Welfare of Hall, 99 Wn.2d 842 (requirement to provide referral list of agencies)
In re Dependency of A.M.M., 182 Wn. App. 776 (what constitutes "necessary services")
Sprague v. Spokane Valley Fire Dep't, 189 Wn.2d 858 (issues not briefed are waived)