In re J.B.

Summary

The Rhode Island Supreme Court affirmed a Family Court decree terminating the respondent father's parental rights to J.B. under G.L. 1956 § 15-7-7(a)(3). The Court held that clear and convincing evidence supported findings that DCYF had offered reunification services, the father failed to meaningfully comply with case-plan requirements, and there was no substantial probability of the child's safe return within a reasonable period. The Court also concluded that termination was in the child's best interests.

Holdings

1. The Family Court properly found by clear and convincing evidence that J.B. had been in DCYF custody for at least twelve months, that services had been offered to address the reasons for placement, and that there was no substantial probability that J.B. could safely return to the father's care within a reasonable period. The father was therefore unfit under § 15-7-7(a)(3).
2. Once the State established the father's unfitness and reasonable reunification efforts, the child's best interests outweighed all other considerations. The Family Court properly found that termination of the father's parental rights was in J.B.'s best interests.

Questions Presented

1. Whether the Family Court clearly erred in finding the father unfit and determining that there was no substantial probability that J.B. could safely return to his care within a reasonable period under R.I. Gen. Laws § 15-7-7(a)(3).
2. Whether termination of the father's parental rights was in J.B.'s best interests.

Disposition

affirmed