In re Shirley B., Jordan B., Davon B., and Cedric B., 419 Md. 1

Summary

The Maryland Court of Appeals considered whether a Department of Social Services made reasonable efforts toward reunification when specialized parenting services were unavailable because of inadequate funding. The court held that the reasonable-efforts inquiry is case-specific and that the Department diligently pursued available avenues to reunification. It also upheld the juvenile court's decision to change the children's permanency plans from reunification to adoption because reunification was not foreseeable and was not in the children's best interests.

Holdings

1. The reasonable-efforts requirement is case-specific and must be evaluated in light of the services and resources available to the Department and related agencies. The Department satisfied that requirement because it made diligent, good-faith efforts to connect the mother with appropriate services, even though funding barriers prevented her from receiving some specialized services.
2. The juvenile court did not abuse its discretion by changing the children's permanency plans from reunification to adoption because the children could not be safely returned to the mother within the foreseeable future and the change served their best interests.

Questions Presented

1. Whether the Department satisfied its statutory obligation to make reasonable efforts toward reunification when specialized services were identified and referrals were made but the services were unavailable because of funding limitations.
2. Whether the juvenile court clearly erred in finding that the Department made reasonable efforts toward reunification.
3. Whether the juvenile court abused its discretion by changing the children's permanency plans from reunification to adoption.

Disposition

affirmed