New York Court of Appeals

Matter of K.Y.Z. (W.Z.)

October 21, 20252025 NY Slip Op 05781

Summary

The Court of Appeals reversed the order terminating the father's parental rights and dismissed the termination petition because the agency failed to prove by clear and convincing evidence that it made diligent efforts to strengthen the parent-child relationship. The agency did not adequately address the father's language needs, provide services directed at the barriers it identified, or assist with housing and employment obstacles affecting reunification. The Court held that minimal efforts cannot satisfy the agency's statutory burden.