AW v. State
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The Supreme Court affirmed the juvenile court's order changing the permanency plan for Mother and Father's four children from reunification to adoption, holding that the juvenile court did not abuse its discretion when it found that the Department of Family Services (DFS) provided reasonable efforts to reunify the children.
After an evidentiary permanency hearing the juvenile court found that reunification with Mother and Father was not in the children's best interests and that reasonable efforts to reunify were no longer required because they had been unsuccessful. The court then changed the plan to adoption. The Supreme Court affirmed, holding (1) the evidence was sufficient for the juvenile court to conclude that reasonable efforts to reunify the children with Mother and Father had been made and no further efforts were required; and (2) the juvenile court did not abuse its discretion in changing the permanency plan from reunification to adoption even though specialized care was not provided to the parents.
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