Annette H. v. State of Alaska, Department of Health & Social Services, Office of Children's Services

Summary

The Alaska Supreme Court affirmed termination of Annette H.'s parental rights because the record supported finding that her son was a child in need of aid based on neglect and that OCS made reasonable efforts to reunify the family. The court held that the child's positive hair follicle test, together with the absence of evidence of exposure elsewhere, supported an inference that conditions in the mother's home caused the exposure even though the precise mechanism was unknown. The court also concluded that OCS adequately accommodated the mother's mental-health-related limitations and that her persistent failure to engage prevented further assessment and services.