§9.33 Chemical Dependency

• Library: Juvenile Law Deskbook (2021 Supp.)

2. (§9.33) Chemical Dependency

Under this factor, “drug use is not grounds for termination, nor is chemical dependency: rather, the statute provides grounds for termination for a chemical dependency ‘which cannot be treated.’” In re D.D.C., 351 S.W.3d 722, 730 (Mo. App. W.D. 2011) (quoting § 211.447.5(2)(b), now RSMo Supp. 2019).

In In re K.M.A.B., 493 S.W.3d 457 (Mo. App. E.D. 2016), the court overturned a father’s termination because, while he repeatedly used marijuana, there was no evidence that he

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