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Appeals court hears challenge to DCF’s ‘reasonable efforts’ after out-of-state placements and reduced visits

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Summary

In the Department of Children and Families v. Mother (24P765) the panel considered whether DCF failed to make reasonable efforts to preserve or reunify the family after placing three children in New York, including whether DCF delayed family therapy and reduced mother’s visitation following the move.

The appellate panel heard argument in the Department of Children and Families v. Mother, docket number 24P765 (impounded), about whether the juvenile court erred after finding DCF had failed to make reasonable efforts — and, if so, whether the agency remedied those failures before trial.

Mother’s argument

Molly Odey, representing the mother (appellant), told the court the record shows repeated requests by the mother for family therapy and that DCF did not implement referrals or meaningful out-of-state visitation arrangements for years. Counsel emphasized that the children were…

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