State Supreme Court: Evidence supports termination of parental rights.

Byline: Barry Bridges

Speaking to the topic for a third time this term, the Rhode Island Supreme Court has upheld the termination of a mother's parental rights, finding no error in Family Court Judge Laureen D'Ambra's conclusion that termination would be in the child's best interests.

Writing for the Supreme Court, Justice Maureen McKenna Goldberg held there was sufficient evidence to support D'Ambra's determination of parental unfitness and that the Department of Children, Youth and Families had made reasonable efforts to strengthen the parental relationship between the respondent mother, Jennifer L., and her now-5-year-old daughter, Violet G.

The record revealed that Jennifer suffers from chronic mental health issues and has been hospitalized numerous times for psychiatric reasons. Her medical history includes multiple suicide attempts and episodes of domestic violence, both as victim and perpetrator.

Jennifer's supervised visits with Violet were "difficult," with the child "visibly distressed" and apprehensive around her mother. Further, Jennifer made little progress in four DCYF case plans that had reunification as the primary goal.

A psychologist testified there was "limited evidence of a positive bond" between mother and child, and ultimately proffered that reunification would present "a significant risk."

D'Ambra found that Jennifer was unfit considering her inability to complete the objectives of her tailored case plans. The judge also found by clear and convincing evidence that Jennifer did not comply with DCYF's efforts to assist with parenting skills and reunification. With no substantial probability that Violet would be able to return to her mother's care within a reasonable time, D'Ambra held that termination of Jennifer's parental rights was in Violet's best interest.

Goldberg affirmed, first pointing to the...