Supreme Court of Delaware

Melissa Brown, Respondent Below, Appellant v. Division of Family Services, Petitioner Below, Appellee

February 14, 201114 A.3d 524

Summary

The Supreme Court of Delaware affirmed the termination of Melissa Brown’s parental rights because the Family Court correctly found that the Division of Family Services made bona fide reasonable efforts to reunify Brown and her child. Those efforts remained reasonable after Brown moved to Connecticut, and the agency was not legally required to pay her interstate visitation travel costs. The court also upheld the Family Court’s factual findings under the applicable deferential standard of review.