In re M.M.R.

In December 2017, the juvenile court took jurisdiction over a child, M.M.R., and placed M.M.R. in foster care. M.M.R.’s mother (the mother) (defendant) had been violent toward M.M.R.’s father (the father) (defendant), and the mother had a variety of other issues, including substance abuse, mental disorders, criminal behavior, and a chaotic lifestyle. The father admitted that his “chaotic relationship” and life with the mother interfered with his ability to safely parent M.M.R., which was alleged by the Department of Human Services (DHS) (plaintiff) as the jurisdictional basis. At different periods of time, two DHS caseworkers offered services to the father. The initial worker referred the father to “Womenspace”; the subsequent caseworker did not know what kind of programs were available at Womenspace or why the referral had been made. The father was also offered services that were essentially given in every case, such as bus passes and cell-phone minutes. The father purchased a motorhome on his own, fulfilling a requirement to acquire safe and stable housing. The father also completed a psychological evaluation and parent training. The father was always appropriate during his consistent visits with M.M.R., who had a very strong bond with the father. The father continued his relationship with the mother because he wanted to help her through her addiction and other issues. DHS did not explicitly require the father and mother to separate. At the permanency-planning hearing, DHS argued, and the court ruled, that the agency had made reasonable efforts to reunify M.M.R. with the father but the father’s efforts had been insufficient to ameliorate the jurisdictional basis. The court ordered a permanent plan of adoption, and the father appealed.