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Name: In re Taylor J.
Case #: B248839
Court: CA Court of Appeal
District 2 DCA
Division: 1
Opinion Date: 02/21/2014

The trial court erred when it found that mother was offered reasonable reunification services where services provided consisted of providing mother with a list of counseling agencies in her vicinity. At a six-month review hearing, mother’s reunification services were terminated because she had not completed court-ordered counseling services. Mother claimed that the counseling services she contacted were not affordable, and she was not given assistance in identifying services she could attend. On appeal, mother argued that there was insufficient evidence to support a finding that the services offered were reasonable. The appellate court agreed and reversed. Although it was undisputed that mother did not comply with the court’s orders to complete domestic violence counseling, it was apparent that DCFS was also to blame. It did not adequately instruct mother on where she could go for counseling, and did not make sure that the services were affordable. Since DCFS did not make a good faith effort to provide reasonable counseling services for mother, the court should not have terminated her services.