Baby Daddy Issues
Yellow Brick Road
to DCCA
Reasonable Efforts
TPR & Adoption
Ta.Hell.
100

When a fit non-custodial parent who has grasped his opportunity interest requests placement at the disposition hearing, the government must show by clear and convincing evidence that placement with that parent is not in the child’s best interests. 

What is In re D.S., 52 A.3d 887 (D.C. 2012)?

100

This order is the final order from which an appeal of a neglect finding may be taken; not the findings of fact and conclusions of law. 

What is the disposition order?  In re A.B., 486 A.2d 1167 (D.C. 1984).

100

It is not enough for a parent to simply go through the motions of a plan, as participation does not equal progress; rather, the parent must meaningfully progress toward remedying                                    , in order to ensure that reunification would be safe and healthy for the child

What are the conditions that led to removal?  What is In re K.C. 200 A.3d 1216(D.C. 2019).

100

The evidentiary standard required to terminate parental rights.

What is clear and convincing? In re Tw.P.756 A.2d 402 (D.C. 2000)

100

The fact that the Agency’s case plan is                 or that it fails to assign responsibility to the tasks therein “did not render the case plan for achieving reunification unreasonable or inadequate.”

What is not signed?  In re J.M. 193 A.3d 773 (D.C. 2018)?   

200

Ending an                       relationship, by itself, is not grounds for a finding of neglect.

What is in loco parentis? In re Fuller v. Fuller, 247 A.2d 767 (D.C. 1968); In re K.J. 11 A.3d 273 (D.C. 2011).

200

What is the authority that states that within 30 days after entry of a magistrate judge order, a party may file a motion for review by an Associate Judge.


What is Family Rule D?

200

There is “no law or precedent of which we are aware that requires [direct referrals for services], and it may well be that the                      of a parent to other referral agencies is quite appropriate if those agencies are most familiar with available resources."

What is Agency's referral? What is In re J.M., 193 A.3d 773(D.C. 2018).

200

A grant of adoption over a natural parent's                 is the “functional equivalent” of an involuntary termination of parental rights.

What is objection?  In re S.M. 985 A.2d 413 (D.C. 2009).

200

Ta.L. is applicable to requests to change from concurrent permanency goals of reunification and adoption to                       .

What is a sole goal of adoption? In re J.M., 193 A.3d 773 (D.C. 2018).

300

A                            by one parent does not divest the court of jurisdiction to make a finding of neglect with regard to a second parent.

What is stipulation?  In re J.W., 837 A.2d 40 (D.C. 2003).

300

Court “must give great deference to the trial court’s factual findings and may not set them aside unless they are plainly wrong or without evidentiary foundation”—in other words, unless they are              .

 

What is clearly erroneous? In re Baby Boy C., 630 A.2d 670 (D.C. 1993).

300

A parent                      the issue of whether CFSA made reasonable efforts towards reunification when the parent repeatedly failed to object to the court’s reasonable efforts findings at every level of the review and permanency hearings.

What is forfeited?  In re D.T., 222 A.3d 593 (D.C. 2019).

300

This case holds once a parent is found unfit, their preference is weighed equally with all other evidence, and the court must decide which placement is in the child’s best interest.


What is In re Petition of J.B.S. & V.S.S. (September 2020)?  

300

The fact that the judge presides over the Ta.L. hearing is not, by itself, enough to establish a lack of impartiality or fundamental fairness when the judge presides over                  .

What is an adoption trial? In re P.D.J.K. 182 A.3d 1234 (D.C. 2018).

400

For a finding of abandonment at a neglect trial, it is sufficient to show that the parent made no reasonable effort to maintain a relationship with the child for at least         months.  

What is four? In re Je.A., 793 A.2d 447 (D.C. 2002).

400

The Court of Appeals has ruled that in contested adoption cases, the matter is not fully and finally resolved until entry of the final                       .

What is the final adoption decree?  In re S.J., 772 A.2d 247 (D.C. 2001).

400

Under                                            , efforts at reunification will be considered reasonable in child neglect case where Child and Family Services Agency (CFSA) has made diligent efforts to encourage participation in the recommended services.

What is the Adoption and Safe Families Act?  In re A.I., 211 A.3d 1116 (D.C. 2019); D.C. Code Sections 4-1301.02(3)(B), 4-1301.09(b).  

400

                      refers to the parent’s intention and ability over time to provide for a child’s wellbeing and meet the child’s needs. 

What is fitness?  In re S.L.G., 110 A.3d 1275 (D.C. 2015).

400

The trial court is prohibited from making this finding about a parent when considering whether to change the goal to adoption.

What is an unfitness finding?  In re Ta.L. 149 A.3d. 1060 (D.C. 2016).

500

In order to develop a custodial relationship, what interest must a noncustodial parent have developed “early on, and continually" to show that he has "done all that he reasonably could have been expected to do under the circumstances to pursue that interest.” 

What is opportunity interest?  In re H.R., 581 A.2d 1141 (D.C. 1990)?

500

If you fail to                      below, the Court of Appeals can only review for “plain error,” which is a much more difficult hurdle to overcome. 

What is to object?  In re T.L., 859 A.2d 1087 (D.C. 2004).

500

If the court makes this finding, the Agency is not required to make reasonable efforts to reunify that parent.

What is aggravated circumstances?  D.C. Code Section 4-1301.09a

Daily Double - Name 2 aggravated circumstances.


500

In addition to the District, this party may also file a TPR.

Who is the guardian ad litem? D.C. Code Section 16-2354(a).

500

This quote comes from what case: "[W]hile permanency hearings in which goal changes are considered [i.e. Ta.L. hearings], now involve formal elements, such as sworn testimony and the creation of transcripts – elements that are typically absent in other kinds of hearings in a neglect case – there appears to be no inherent need or logic that mandates excluding hearsay,". 

What is the concurring opinion by Judge Glickman from In re Z.W? 214 A.3d 1023, 1051 (D.C. 2019).