Supreme Court of Rhode Island

In Re Gabrielle D.

March 26, 20122012 R.I. LEXIS 29

Summary

The Rhode Island Supreme Court affirmed the Family Court’s termination of parental rights of Armand D., holding that the Department of Children, Youth and Families satisfied the statutory requirement of reasonable efforts to reunify the child, even though services were obtained outside the agency. The opinion also notes that the Court’s reasoning on reasonable efforts differs from that in In re Steven D., a point highlighted in a concurring opinion.