In Violet C. v. State, Department of Health & Social Service,[1] the supreme court held that the Office of Child Services (OCS) must make reasonable efforts to provide services to parents who face permanent termination of their parental rights, but its efforts need not be perfect. Following concerns over the mother’s substance abuse and the father’s incarceration in another state, OCS assumed custody of the children. After the mother notified OCS of her hearing disabilities and transportation issues, OCS provided her with accommodations, including transportation services. Although the transportation services were sometimes unavailable, the mother sometimes failed to take advantage of services arranged by OCS even when she had transportation available. OCS also tried to contact the father and set up services for him in Texas but was often unable to reach him through the contact information he provided, his attorney, or the jail. On appeal, both parents argued OCS’s efforts were not reasonable, as required by law. The supreme court ruled OCS’s efforts were reasonable even though they were not perfect. The court emphasized that a parent’s willful failure to participate in treatment could be considered when determining if OCS’s efforts were reasonable. Affirming the trial court’s permanent termination of parental rights, the supreme court held that OCS’s efforts to provide services to parents who face termination of their parental rights must be reasonable but need not be perfect.
[1] 436 P.3d 1032 (Alaska 2019).
