Supreme Court of Rhode Island

In Re Gabrielle D. — Goldberg, J., Concurring

March 26, 20122012 R.I. LEXIS 29

Summary

Justice Goldberg concurs with the majority’s affirmation of the termination decree and emphasizes that the statutory requirement of reasonable efforts is satisfied when a parent obtains counseling and related services outside of DCYF. He contrasts this result with In re Steven D., arguing that the earlier case should be limited to its unique facts. The concurrence underscores that the source of services is irrelevant so long as the parent receives them.