In re Violet G., 212 A.3d 160

DCYF filed to involuntarily terminate Jennifer L.’s parental rights to her daughter Violet (born Dec. 24, 2013); neglect petition was consolidated with the termination proceedings.
Proceedings followed more than two years of DCYF involvement after concerns including respondent’s repeated psychiatric hospitalizations, suicide attempts, substance-use questions, and domestic-violence incidents.
Four DCYF case plans emphasized mental-health treatment, medication compliance, substance-abuse services, domestic-violence counseling, and supervised visitation; visitation proved difficult and distressing to Violet.
Dr. John Parsons (clinical psychologist) evaluated respondent, diagnosed bipolar disorder with psychotic features, found unstable mood and limited insight/protective capacity, and opined reunification posed significant risk.
The Family Court found by clear and convincing evidence that respondent was unfit, that DCYF made reasonable efforts to reunify, and that termination was in Violet’s best interests; Supreme Court affirmed.

Issue	Petitioner (DCYF) Argument	Respondent (Jennifer) Argument	Held
Whether respondent is unfit to parent	Respondent’s chronic, uncontrolled mental illness, failure to comply with case plans, volatile behavior, and history made reunification improbable	Record insufficient to show unfitness	Court: Unfitness proven by clear and convincing evidence
Whether DCYF made reasonable efforts to reunify	DCYF provided four case plans, referrals, supervised visitation, and services over two+ years	DCYF failed to make adequate or appropriate efforts (argued)	Court: DCYF made reasonable (indeed extensive) efforts
Whether termination was in child’s best interest	Violet was traumatized by visits; no maternal bond; child needs stable permanent home	Termination severed parent-child bond and was premature	Court: Best interests favored termination and adoption by foster family
Standard of review / sufficiency of evidence	Family Court findings entitled to great weight if supported by clear and convincing evidence	Challenge to factual findings as unsupported	Court: Findings supported by legally competent evidence; affirmed

In re Amiah P., 54 A.3d 446 (discussing review standard and weight of Family Court findings)
In re Victoria L., 950 A.2d 1168 (family-court factual findings entitled to great weight)
In re Destiny D., 922 A.2d 168 (parental liberty interest in child-rearing)
In re Jazlyn P., 31 A.3d 1273 (best interests of the child outweigh other considerations after unfitness found)
In re Jennifer R., 667 A.2d 535 (standard for upholding findings of parental unfitness)
In re Lauren B., 78 A.3d 752 (DCYF must make reasonable — not extraordinary — reunification efforts)
In re Jose Luis R.H., 968 A.2d 875 (scope of reasonable efforts by agency)
In re Joseph S., 788 A.2d 475 (reasonableness of efforts assessed case-by-case)
In re Kristen B., 558 A.2d 200 (same)
In re Kristina L., 520 A.2d 574 (best-interest analysis governs after unfitness)
In re Alexis L., 972 A.2d 159 (importance of children having a safe, nurturing permanent home)