In Re Steven D.

Summary

The Rhode Island Supreme Court vacated the Family Court decree terminating the parental rights of Kathleen D. and Ronald D., finding that the trial justice erred in concluding that the Department of Children, Youth and Families (DCYF) made reasonable efforts to reunify Kathleen and in finding Ronald unfit. The Court held that DCYF failed to offer or refer Kathleen to appropriate alcohol treatment despite identifying it as a barrier to reunification, and that the trial justice provided insufficient factual findings to support Ronald's unfitness. The record was remanded to the Family Court. Justice Suttell, concurring in part and dissenting in part, argued that the majority erred and would have affirmed the termination for Kathleen.