Reasonable reunification efforts; § 19b(3)(c)(i)

The trial court did not commit plain error affecting respondent-father’s substantial rights when it determined the DHHS made reasonable efforts to facilitate reunification. Also, § (c)(i) existed as to both respondents. He argued the DHHS “failed to make reasonable efforts toward reunification because it did not ensure that the . . .  service providers were complying with the recommendations contained in his psychological and substance abuse evaluation.” Specifically, he asserted that there was “no indication his counselors followed the recommendation to encourage him to open up and stop engaging in denial.” Although the record reflected “that only one of his many counselors was provided with copies of the evaluations, given the record in this case, it is apparent that his participation with each service provider was sporadic and short-lived. The caseworker was not always able to communicate freely with the counselors and information on his progress was not always available because [the father] did not sign the appropriate paperwork. Moreover, even if the recommendations had been given to each of the providers, there is nothing on this record suggesting that respondent-father’s history of changing providers and failure to demonstrate any meaningful benefit from the counseling would have been different.” As to § (c)(i), the court found that “the conditions that led to adjudication continued to exist. Moreover, the trial court did not clearly err by finding that respondent-father would be unable to rectify his issues with domestic violence within a reasonable time considering the minor child’s age.” At the time of termination, the “child was 6 ½ years old, had extensive special needs, and had been out of [the father’s] care for most of his life. Despite having received reunification services aimed at rectifying his issues with domestic-violence for over two years, [the father] made no significant progress. He was still engaging in domestic-violence with the child’s mother.” Also, while “respondent-mother seemed to have ended her relationship with [the father] at the time of the May 2024 termination, [she] still refused to engage in domestic violence services.” Affirmed.