The Appellate Group

In re P.J.R

In re P.J.R, 2023 UT App 27 (Harris, J.)


Mother challenged the termination of her parental rights claiming DCFS did not make reasonable efforts to reunite her and Child. On appeal, Mother argued that (1) the juvenile court should have applied the “clear and convincing evidence standard” in making its reasonable efforts determination, and (2) the juvenile court’s reasonable efforts determination was incorrect. The Court of Appeals affirmed, stating: 

  • A juvenile court’s reasonable efforts determination must be supported by clear and convincing evidence. Here, the juvenile court correctly relied on the “clear and convincing evidence” standard.
  • The juvenile court did not abuse its discretion in its reasonable efforts determination, because it specifically addressed Mother’s arguments in its ruling.

Read the full court opinion