In re Manuel P., In re Angel P., In re Isaiah M., In re Victoria M.

Syllabus

The respondent mother appealed from a decree terminating her parental rights to four of her children. On appeal, the respondent argued that the trial justice violated her right to procedural due process by proceeding with trial in her absence, following another court's determination that she was incompetent to stand trial in a criminal matter. The respondent also contended that DCYF failed to establish that it made reasonable efforts to strengthen the parental bond and offer services aimed at reunification, as the department is required to do under G.L. 1956 §§ 15-7-7(a)(3) and 15-7-7(b)(1). The Supreme Court determined that the respondent's due process rights were not violated, because the Family Court trial justice ensured that respondent was represented by counsel and a guardian ad litem at all times. Additionally, the Supreme Court held that there was legally competent evidence to support the trial justice's findings regarding the reasonableness of DCYF's efforts, by clear and convincing evidence. Finally, the Court determined that the decision of the Family Court was in the best interests of the children, who had found stability with their respective foster families. Accordingly, the Court affirmed the decree of the Family Court.