In re Tiara E.

Syllabus

The respondent father appealed from the judgment of the trial court for the petitioner, the Commissioner of Children and Families, terminating his parental rights as to his minor child. He claimed, inter alia, that the court, in making its determination that the Department of Children and Families had made reasonable efforts to reunify him with his child, improperly relied on information contained in a social study that had been admitted into evidence and that he claimed was tinged with possible bias. Held: There was sufficient evidence in the record to support the trial court's conclusion that the department made reasonable efforts to reunify the respondent father with the child, as the father merely alleged that the social studies report was possibly biased and did not object to or challenge at trial any of the subordinate factual findings in the report, and there was no evidence that the department did not make the reasonable efforts it claimed to have made. The trial court did not err in its determination that the respondent father was unable or unwilling to benefit from the department's proffered services, as the father failed to demonstrate that the facts alleged in the termination petition were insufficient to sustain the court's judgment. Argued March 10—officially released April 10, 2025