Shirley M. v. State, Dept. of Health & Social Services, Office of Children's Services

Summary

The Alaska Supreme Court affirmed termination of Shirley M.'s parental rights to Abigail and upheld the decision to keep Abigail placed with her foster family. The court held that Shirley failed to remedy the conditions placing Abigail at risk within a reasonable time, that OCS made reasonable reunification efforts, and that termination served Abigail's best interests. The court also held that clear and convincing evidence supported deviation from any applicable relative-placement preference because of Abigail's significant special needs and Rae's inability to meet them.