Supreme Court of Rhode Island

In Re Gabrielle D.

March 26, 20122012 R.I. LEXIS 29

Summary

The Supreme Court of Rhode Island affirmed the Family Court's termination of parental rights, holding that the Department of Children, Youth and Families satisfied the statutory requirement of reasonable efforts to reunify because the father was receiving independent counseling, and therefore the decree was supported by clear and convincing evidence. Justice Goldberg filed a concurring opinion noting the contrast with In re Steven D.