In the Matter of the Welfare of the Child of: D. C., Parent., A16-996

Mother (D.C.) is biological parent of D.M.C.; county petitioned to terminate her parental rights after multiple child-protection involvements and out-of-home placements.
Prior CPS history (2008–2009, 2013–2014, 2015) included parenting services, convictions for malicious punishment of a child, and children placed with a relative; criminal and safety incidents included physical abuse findings and a DWI.
In April 2015 children were removed after reports the mother choked and threatened a child; D.M.C. was placed with a relative and remained out of the mother’s care through termination proceedings.
County provided a case plan (May 2015) requiring parenting education, mental-health and chemical-dependency assessments, anger management, and counseling; mother frequently failed to engage, moved between Minnesota and Nebraska, and did not keep the county informed of her whereabouts.
Psychological and parenting evaluations (completed during trial) diagnosed PTSD, alcohol-use disorder, personality disorder features, and concluded prognosis was poor without long-term treatment; evaluators warned of risk to the child.
District court found statutory grounds for termination, concluded the county made reasonable efforts to reunify, and terminated parental rights; Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the county made reasonable efforts to reunify D.C. and D.M.C.	County failed to provide services promptly, did not follow through on referrals after evaluations, and thus did not make reasonable efforts.	County provided extensive, individualized services over multiple CPS involvements; mother’s repeated nonengagement, moves across states, and failure to keep contact impeded services; further services would be futile.	Court affirmed: county made reasonable efforts; district court’s finding not clearly erroneous.

In re Welfare of Children of S.E.P., 744 N.W.2d 381 (Minn. 2008) (standard for appellate review and requirements for termination proceedings)
In re Welfare of Children of T.R., 750 N.W.2d 656 (Minn. 2008) (county must provide services tailored to parental limitations)
In re Welfare of Children of J.K.T., 814 N.W.2d 76 (Minn. Ct. App. 2012) (factors for assessing reasonable efforts include length, nature, and quality of effort)
In re Welfare of Children of J.R.B., 805 N.W.2d 895 (Minn. Ct. App. 2011) (review standard for factual findings in termination cases)
In re Welfare of L.A.F., 554 N.W.2d 393 (Minn. 1996) (district court’s superior position to assess witness credibility)
In re Welfare of Children of S.W., 727 N.W.2d 144 (Minn. Ct. App. 2007) (reasonable efforts require real, genuine assistance beyond mere form)