The Washoe County Department of Social Services (plaintiff) took custody of Jacqueline G.’s (defendant’s) four children after receiving several reports that she lacked adequate housing for them. From October 2012 until July 2015, Jacqueline lived in approximately 15 different apartments, shelters, and motels. The department provided a case plan; referred her for psychological counseling; gave her money for a hotel room, furniture, and childcare supplies; and helped her apply for jobs and prepare for interviews. But Jacqueline failed to keep any job more than a month, quitting several voluntarily; did not apply for crime-victim funds or submit documents necessary to obtain low-income utility assistance; failed to find an apartment even with a Section 8 housing voucher; and did not show up for therapy. After two years, the department petitioned to terminate her parental rights. Following trial, the court found Jacqueline had demonstrated only token efforts to comply with her case plan and care for her children and terminated her parental rights as in the children’s best interests. Jacqueline appealed, arguing that poverty alone is not enough to terminate parental rights.