State ex rel. Children, Youth & Families Dept.
Court of Appeals of New Mexico
47 P.3d 859 (2002)
Patricia (defendant), battling a thyroid disorder and breast cancer, requested CYFD (plaintiff) take custody of her rebellious, highly-needs daughter Elizabeth at age four and a half; despite a stipulated agreement and multiple permanency hearings contemplating eventual reunification, Patricia's scheduled visits went poorly, and after two and a half years in CYFD custody, the district court terminated her parental rights, with Patricia appealing on the ground that CYFD failed to make reasonable efforts to help her address the issues causing Elizabeth's neglect.
Whether a state child-protection agency must make reasonable efforts to assist a parent before the state may terminate parental rights.