In the Interest of T. B. W., 312 Ga. App. 733

The juvenile court found T. B. W. deprived and placed temporary custody with the Department on October 5, 2010.
The deprivation order followed a July 8, 2010 order based on the mother's stipulation of medical neglect; the child already was in Department custody.
The child was born with brain damage requiring constant medical care; there is no evidence she ever lived with the father or that the parents cohabitated.
The court had ordered the putative father to establish paternity and complete several programs and tasks before reunification could occur.
A Department caseworker began working with the father in July, arranged visitation, and prepared a reunification case plan, but the father failed to meet key requirements.
The court concluded it would be contrary to the child’s welfare to be with the father at that time, but continued theDepartment’s custody with a plan for reunification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the Department make reasonable efforts to prevent removal?	Father contends no reasonable efforts were shown.	Department showed extensive efforts to preserve and reunify the family.	Yes; findings supported that reasonable efforts were made.
Is deprivation proper independent of reunification efforts?	Deprivation should hinge on reunification efforts.	Deprivation and custody are separate inquiries; deprivation may be found regardless of reunification status.	Deprivation may be found independent of reunification efforts; the record supports the court’s disposition.

In the Interest of D. W., 264 Ga. App. 833 (2003) (parental standing and deprivation framework)
In the Interest of R. M., 276 Ga. App. 707 (2005) (deprivation standard and reunification context)
In the Interest of A. R., 287 Ga. App. 334 (2007) (separate inquiries on deprivation and disposition)
Hall v. Hall, 222 Ga. 820 (1966) (fathers’ standing when illegitimate child not legitimated)