In Interest of K.F.

Karen (defendant), the mother of nine-year-old Kristi, suffered from paranoid schizophrenia. As a result of Karen’s mental illness, she was involuntarily committed 11 times in four-and-a-half years, during which Kristi was placed in various foster homes. Following the latest involuntary commitment, Kristi was again judged a child in need of assistance (CINA) and placed in emergency foster care. Karen’s psychiatrist, Dr. Chang, reported that Karen’s delusions could not be entirely controlled by medication. Dr. Chang testified that Karen’s illness was characterized by cycles in which she would take her medication and function normally, followed by periods when she would stop taking her medication, lose touch with reality, and potentially become violent. Accordingly, Dr. Chang predicted that Karen would stop her medication and quickly become psychotic as soon as custody was restored and she was no longer subject to court oversight. The state (plaintiff) petitioned to terminate Karen’s parental rights, and the juvenile court granted the petition. Karen appealed, and the court of appeals reversed the juvenile court’s ruling, holding that Karen had made steady improvement, that reunification should be the goal, and that there was insufficient proof Karen would fail to properly care for Kristi going forward. The state appealed.