The Appellate Group

In re B.J.

In re B.J., 2026 UT App 144 (Tenney, J.)

Child Welfare

The Utah Court of Appeals held:

(1) The juvenile court did not err in finding that DCFS made reasonable efforts at providing reunification services in this case.
(2) The juvenile court did not err in concluding that DCFS provided reasonable accommodations as required by the ADA because [1] it does not appear that Mother invoked the ADA to request the particular accommodations at issue, and [2] even if she had, Mother did not persuade the court of appeals that the accommodations would have mattered.
(3) The juvenile court did not err in concluding that termination of Mother’s parental rights was in the children’s best interests.

Practice tip:

If DCFS subsequently asks a court to terminate the parent’s rights, the parent is not foreclosed from arguing in response that the prior proceedings cannot be used as support for that petition because DCFS failed to make reasonable efforts at providing reunification services during the earlier removal proceedings.

Read the full court opinion