In re D.R.
In re D.R., 2022 UT App 124 (Christiansen Forster, J.)
Mother failed to meet her reunification goals. She later asked the juvenile court to reinstate reunification services on vague ADA grounds. The court subsequently terminated reunification services and eventually terminated parental rights. Mother appealed. The Court of Appeals affirmed, holding:
- The juvenile court did not exceed its discretion when it rejected Mother’s ADA argument. The juvenile court has no affirmative obligation to identify potential reasonable accommodations that the parent did not request under the ADA merely because the court is aware that the parent has been diagnosed with something.
- Mother has not demonstrated that she received ineffective assistance of counsel warranting remand under Rule 23B because she has not provided the court with a non-speculative evidentiary proffer in support of her ADA claim.