Cited by

See Donald W. v. Dep’t of Child Safety, ¶ 49 (App. 2019).

., maintain consistent contact with the parent, and make reasonable efforts to assist the parent in areas where compliance proves difficult.” Donald W. v. Dep’t of Child Safety, ¶ 50 (App. 2019).

DCS should also “maintain consistent contact with the parent” and “make reasonable efforts to assist the parent in areas where compliance proves difficult.” Donald W. v. Dep’t of Child Safety, ¶ 50 (App. 2019).

And DCS must “maintain consistent contact with the parent[] and make reasonable efforts to assist the parent in areas where compliance proves difficult.” Donald W. v. Dep’t of Child Safety, ¶ 50 (App. 2019).

at ¶ 15 (citation omitted), and must maintain consistent contact with the parent and reasonably assist him or her in areas where compliance proves difficult, Donald W. v. Dep’t of Child Safety, ¶ 50 (App. 2019).

She relies on Donald W. v. Dep’t of Child Safety

court-ordered out-of-home care; and (4) there was ‘a substantial likelihood that [the parent would] not be capable of exercising proper and effective parental care and control in the near future.’” Donald W. v. Dep’t of Child Safety, ¶ 25 (App. 2019) (quoting A.R.S.

at the least—DCS to identify the conditions causing the child’s out-of-home placement, provide services that have a reasonable prospect of success to remedy the circumstances as they arise throughout the time-in-care period, maintain consistent contact with the parent, and make reasonable efforts to assist the parent in areas where compliance proves difficult.” Donald W. v. Dep’t of Child Safety, ¶ 50 (App. 2019) (citation and emphasis omitted).

See Donald W. v. Dep’t of Child Safety, ¶ 50 (App. 2019) (noting that “diligent effort” requires DCS to “make reasonable efforts to assist the parent in areas where compliance proves difficult”); see also Kyle R. v. Dep’t of Child Safety, No. 1 CA-JV 22-0048, 2022 WL 6612638, *4, ¶¶23–24 (Ariz. App. Oct.

¶ 25 (App. 2019); see also Jessie D. v. Dep’t of Child Safety, ¶ 18 (2021) (stating that DCS is “require[d] to engage in reunification efforts ‘on constitutional grounds as a necessary element of any state attempt to overcome .

See Donald W. v. Dep’t of Child Safety, ¶ 49 (App. 2019).

§ 8-533(B)(8)(c); see also Donald W. v. Dep’t of Child Safety, ¶ 25 (App. 2019).

and make[s] reasonable efforts to assist the parent in areas where compliance proves difficult.” Donald W. v. Dep’t of Child Safety, ¶ 50 (App. 2019).

The juvenile court must “consider the totality of the circumstances when determining whether [the Department] has made diligent efforts.” Donald W. v. Dep’t of Child Safety, ¶ 49 (App. 2019).

he least” DCS must “identify the conditions causing the child’s out-of-home placement, provide services that have a reasonable prospect of success to remedy the circumstances as they arise throughout the time-in-care period, maintain consistent contact with the parent, and make reasonable efforts to assist the parent in areas where compliance proves difficult.” Donald W. v. Dep’t of Child Safety, ¶ 50 (App. 2019).

Donald W. v. Dep’t of Child Safety, ¶ 50 (App. 2019) (emphasis omitted).

The court must “consider the totality of the circumstances when determining whether DCS has made diligent efforts.” Donald W. v. Dep’t of Child Safety, ¶ 49 (App. 2019).

Decision of the Court reasonable efforts to provide these services.”); Donald W. v. Dep’t of Child Safety, ¶ 26 (App. 2019) (noting that before parental rights can be terminated under A.R.S.

The juvenile court must “consider the totality of the circumstances when determining whether DCS has made diligent efforts.” Donald W. v. Dep’t of Child Safety, ¶ 49 (App. 2019).

.” Donald W. v. Ariz. Dep’t of Child Safety, ¶ 50 (App. 2019).

Donald W. v. Dep’t of Child Safety, 26 ¶¶ 49, 69 (App. 2019) (explaining that courts must consider the entire dependency and weigh the totality of the circumstances).

Donald W. v. Dep’t of Child Safety, ¶ 50 (App. 2019).

§ 8–533(B)(8)(c); Donald W. v. Dep’t of Child Safety, ¶ 25 (App. 2019).

Sec., ¶ 8 (App. 2004))); see also Donald W. v. Dep’t of Child Safety, ¶ 49 (App. 2019) (explaining that “DCS must make diligent efforts” throughout “the entire time [DCS’] case plan is [family] reunification,” and the court must “consider the totality of the circumstances when determining whether DCS has made diligent efforts”).

The court of appeals’ –19 ¶¶ 27– 30 (App. 2019), as support for this putative power is misplaced.

See Donald W. v. Dep’t of Child Safety, ¶ 49 (App. 2019) (DCS is required to make diligent efforts “[while] the case plan is reunification”).