Watson v. Division of Family Services and Office of Child Advocate

Summary

The Supreme Court of Delaware affirmed the termination of Mother’s parental rights under 13 Del. C. § 1103(a)(5). It held that the Family Court properly found Mother failed to plan for the children’s safe return because she repeatedly maintained contact with Father, exposed the children to risks associated with his domestic violence, and failed to maintain stable housing, rather than because she was herself a domestic-violence victim. The Court also held that the Family Court properly considered the prison-call recordings and related evidence.