In Re Elijah C.

Summary

The court held that the Appellate Court improperly dismissed the respondent's appeal as moot because her challenge to the finding that she could not benefit from reunification services was minimally but adequately briefed. On the merits, the court concluded that clear and convincing evidence supported that finding, which independently sustained the termination judgment, so it did not decide whether the department's reunification efforts were reasonable or complied with the ADA. The court also clarified that the ADA informs the department's reunification obligations but is not a defense to a termination proceeding.