Wash. Rev. Code § 13.34.180

RCW 13.34.180 governs termination of an established natural father's parental rights.

Rogers v. Rogers · filed 1982-03-04

If Rogers is a "parent", his relationship to Theresa is decided under RCW 13.34.180. ... Here, there is no question Rogers was the natural father. He is therefore no longer merely alleged, or thought to be, but actually is the father and is a "parent".

Section 13.34.180's dependency termination standards apply when a man is declared the natural father before the termination hearing, even if proceedings began before the declaration.

In Re the Adoption of Baby Boy C. · filed 1982-06-03

Reading these acts together we hold that where a decree under the Uniform Parentage Act is entered which establishes a man as being the natural father of the child before the hearing on the termination of his parental rights, such rights can only be terminated by the parent termination standards in dependency petitions. ... This is so even though the decree on parentage was entered after the termination proceedings were initiated.

Former RCW 13.34.180 allowed a child-placing agency involved in the dependency proceeding to petition for termination of parental rights.

New Hope of Washington v. Ramquist · filed 1988-12-12

We conclude that former RCW 13.34.180 grants New Hope standing. The 1988 amendment simply confirms what was implicit in the statutory scheme.

Section 13.34.180 allows a child welfare agency that is a party to a dependency proceeding to file a termination petition.

Tucker v. Lutheran Social Services · filed 1990-01-22

Pursuant to RCW 13.34.180, CCS and LSS, as parties to the dependency proceedings in each case, had standing to file termination petitions.

Section 13.34.180 permits a religiously affiliated child welfare agency to file a termination petition without excessive entanglement with religion when the court makes the termination decision.

Lutheran Social Services of Washington & Idaho, Inc. v. Ludden · filed 1992-01-13

Applying the law as set forth in Grendel's Den and the rationale set forth in J.L.T., we hold that excessive entanglement of government and religion has not occurred through LSS's participation in the dependency and termination process. ... The only discretionary decision made by LSS was whether to file the termination petition, and that specific portion of the statute was found not to create excessive entanglement in J.L.T.

Section 13.34.180 does not give former legal custodians who are neither legal nor de facto parents a right to participate in proceedings to terminate a biological parent's rights.

In Re Dependency of Dm · filed 2006-12-20(1)

But after the juvenile court vacated their non-parental custody decree, Janice and Charles were no longer entitled to participate in the children's dependency; nor were they legally entitled to participate in the biological mother's parental termination proceedings. These rights extend only to those parties to whom the Legislature has given legal "parent" status under RCW 13.34.180 and 13.34.190. And Janice and Charles do not fall within any of these statutory categories.

A former nonparental custodian whose custody decree has been vacated is not entitled to participate in proceedings to terminate a biological parent’s rights under § 13.34.180.

Janice M. v. Department of Social & Health Services · filed 2006-12-20(1)

Until the juvenile court vacated Janice and Charles’ status as legal custodians, they were parties to the children’s dependency proceedings. But after the juvenile court vacated their nonparental custody decree, Janice and Charles were no longer entitled to participate in the children’s dependency proceedings, nor were they legally entitled to participate in the biological mother’s parental termination proceedings. These rights extend only to those parties to whom the legislature has given legal “parent” status under RCW 13.34.180 and 13.34.190. And Janice and Charles do not fall within any of these statutory categories.

Section 13.34.180(1)(f) provides protections for incarcerated parents in dependency termination proceedings, but those protections do not apply in adoption proceedings.

In Re The Adoption Of C.t.k.m.: Thomas Mcmahon v. Timothy & Tammy Dehnhoff · filed 2016-02-16(1)(f)

RCW 13.34.180(1 )(f). These protections appear only in the dependency statute, not the adoption statute, so they do not apply in adoption proceedings.

RCW 13.34.180(1)(f) applies to dependency actions, not private parenting plan actions under chapter 26.09 RCW.

Randhawa v. Olga v. Shkarina · filed 2024-06-25(1)(f)

But chapter 13.34 RCW applies to dependencies, which are actions in which the State is taking away parental rights. That chapter does not apply to parenting plans under chapter 26.09 RCW, which are private actions between parties that allocate rather than eliminate the parties’ parental rights. Accordingly, this argument fails.

Section 13.34.180 permits a termination petition to proceed before parentage is established when the alleged parent’s refusal to comply with orders to establish parentage caused the delay and the court affords the protections available to parents.

In Re the Interest of: B.R. · filed 2026-03-10

To the extent TH argues that the trial court should have honored the limitations of the dependency and termination statutes by waiting to initiate termination until after parentage was established, despite TH’s own persistent refusal to cooperate, we decline to adopt this approach.

Section 13.34.180 makes dependency one of several factors considered when terminating parental rights.

In Re the Welfare of Dodge · filed 1981-06-01

In determining whether to permanently deprive a parent of all parental rights, dependency is only one factor to be considered.

Section 13.34.180(3) permits a dependency finding made under the former statutory definition to support termination when the change in definition does not invalidate that finding.

In Re the Welfare of Henderson · filed 1981-07-02(3)

Because of this requirement, a literal reading of this statute would prevent parental rights from being terminated in any case where the initial dependency determination, as here, was made under the former definition contained in RCW 13.04-.010. Such an interpretation would thwart the legislative intent to have courts act in the best interests of the child, and accordingly we reject such an interpretation.

Section 13.34.180(1) does not require a dependency order to state that the child is dependent as to a particular parent.

In Re the Welfare of Fisher · filed 1982-04-16(1)

Further, Fisher's primary contention is that under RCW 13.34.180(1) the child was not found to be dependent as to him. We do not agree. An order was entered on December 19, 1978, finding the child to be dependent. Dependency as defined in RCW 13.34.030(2) relates to the child's status of being abandoned, abused or neglected by its parent, guardian or other custodian. There is no requirement that an order of dependency specifically state that the child is found to be dependent as to a particular parent, guardian or custodian. Such a determination is implicit in a finding of dependency.

Section 13.34.180(1) and (2) require proof that the child was found dependent and a dispositional order was entered, without relitigating the facts supporting dependency.

In Re KR · filed 1995-11-09(1)-(2)

Thus, contrary to the Joneses' assertions, RCW 13.34.180 does not require the State to reprove the facts supporting the dependency by clear, cogent, and convincing evidence. Allegations (1) and (2) only require the State to prove by clear, cogent, and convincing evidence that the children have been found to be dependent under RCW 13.34.030 and that dispositional orders have been issued.

Section 13.34.180(1) and (2) require proof of a dependency finding and a dispositional order, without requiring the State to reprove the facts underlying dependency.

Department of Social & Health Services v. Jones · filed 1995-11-09(1)-(2)

Thus, contrary to the Joneses’ assertions, RCW 13.34.180 does not require the State to reprove the facts supporting the dependency by clear, cogent, and convincing evidence. Allegations (1) and (2) only require the State to prove by clear, cogent, and convincing evidence that the children have been found to be dependent under RCW 13.34.030 and that dispositional orders have been issued.

Section 13.34.180 does not require the State to relitigate the facts underlying a dependency at the termination trial.

State v. Safouane · filed 2000-04-24

Here, although the trial court properly held that collateral estoppel did not apply, the trial court erred in requiring DSHS to relitigate the facts of Mohammed’s death at the termination trial because such an explicit finding was not required.

Section 13.34.180 does not require the State to reprove the facts underlying a dependency at the termination trial; proof of its elements implicitly establishes current parental unfitness.

In Re Dependency of As · filed 2000-06-05

Rather, the court stated that an implicit finding of current parental unfitness has been made when DSHS proves the elements of RCW 13.34.180 at the termination trial. Thus, although the trial court properly held that collateral estoppel did not apply, the trial court erred in requiring DSHS to relitigate the facts of Mohammed's death at the termination trial because such an explicit finding was not required.

Section 13.34.180(1)(a) requires a prior finding of dependency before parental rights may be terminated; an independent finding in a dependency review order can satisfy that requirement even if the initial dependency order is void.

In Re Dependency of Knj · filed 2009-07-20(1)(a)

Following McCrillis, we conclude the order of dependency filed by the judge pro tempore on April 19, 2006 is not a valid order for purposes of satisfying RCW 13.34.180(1)(a) in the termination trial. Following Henderson and A.W., we conclude the defect was cured by the dependency review orders in which constitutionally qualified judges independently found KNJ dependent.

Section 13.34.180(1)(a)’s dependency requirement may be satisfied by findings at the termination trial if the facts and circumstances clearly show that the trial court intended to find the child dependent.

Jenkins v. Department of Social & Health Services · filed 2011-05-26(1)(a)

We affirm because findings of fact entered at the termination trial may sufficiently establish dependency, but only if, as here, the facts and circumstances clearly demonstrate the omitted finding was actually intended by the trial court.

Section 13.34.180(1)(a)’s dependency requirement may be satisfied by findings made at the termination trial if the facts and circumstances clearly show that the trial court intended to find the child dependent.

In Re Dependency of KNJ · filed 2011-08-02(1)(a)

We affirm because findings of fact entered at the termination trial may sufficiently establish dependency, but only if, as here, the facts and circumstances clearly demonstrate the omitted finding was actually intended by the trial court.

Section 13.34.180(1)(a) requires proof that the child has been found dependent; a merely voidable dependency order cannot be challenged collaterally to defeat that requirement.

In Re The Dependency Of S.e.r., Kizzy Reid v. Dshs · filed 2019-09-23(1)(a)

Reid claims that the State did not meet its burden of proving at the termination hearing that S.E.R. was a dependent child because the dependency order was void.2 We disagree. ... These inconsistencies do not make the order void. At best, they make it voidable. So Reid may not collaterally attack the validity of the dependency order.

Section 13.34.180(1)(a) requires a finding of dependency for termination; independent findings at the termination trial can establish dependency even if the earlier dependency order is void.

In Re The Dependency Of: J.w., A.w. & D.w. · filed 2019-09-04(1)(a)

In order to terminate the parent-child relationship, the State must prove, among other elements, “[t]hat the child has been found to be a dependent child.” RCW 13.34.180(1)(a). ... Here, independent findings of fact establish dependency. ... Accordingly, DW’s appeal is moot because voiding the dependency order would have no effect on the termination of his parental rights.

Section 13.34.180(4) requires that a parent be offered all necessary, reasonably available services capable of correcting parental deficiencies within the foreseeable future.

Department of Social & Health Services v. Ferguson · filed 1983-01-13(4)

We hold that there is sufficient evidence to support the trial court's termination of Frank Ferguson's parental rights in his minor son. Under the specific facts of this case, all services reasonably available to correct Mr. Ferguson's parental deficiencies were offered.

Section 13.34.180(4) requires the State to provide a parent with a referral list when it suggests remedial services.

In Re the Welfare of Hall · filed 1983-06-16(4)

When the State suggests remedial services to a parent, it has an obligation under RCW 13.34.180(4) to at least provide him or her with a referral list of agencies or organizations which provide the services.

Section 13.34.180(4) requires the State to offer or provide necessary, reasonably available services capable of correcting parental deficiencies before terminating parental rights; a parent's refusal to cooperate does not mean the State failed to offer them.

Ott v. State · filed 1984-02-06(4)

Mr. Ott first challenges the trial court's finding that, prior to seeking termination, the State provided "all necessary services, reasonably available, capable of correcting the parental deficiencies within the foreseeable future . . .". RCW 13.34.180(4). We find ample evidence that the State offered the necessary services. The record is also clear that Mr. Ott resisted the State's efforts to stabilize his housing situation and to provide him with psychological counseling. It was not the lack of services, but Mr. Ott's refusal to cooperate with them, that led to the order of termination.

Section 13.34.180(4) is satisfied when all necessary, reasonably available services are offered, even if the parent does not successfully use them.

Ferguson v. Department of Social & Health Services · filed 1985-05-20(4)

The evidence is overwhelming that all necessary services reasonably available were offered to Mr. Ferguson, but he was unwilling or unable to successfully utilize them and overcome his deficiencies as a parent. The trial court did not err by finding that there was compliance with RCW 13.34.180(4), even though there was disputed testimony.

Section 13.34.180(4)'s reasonable-services requirement may be satisfied even when the State denies visitation because contact would harm the child.

In Re the Welfare of Siegfried · filed 1985-11-27(4)

It was reasonable to deny visitation based on Valerie's best interests. There was, therefore, sufficient evidence to support the finding that all reasonable services had been offered.

Section 13.34.180(4) requires the State to offer or provide necessary services capable of correcting parental deficiencies within the foreseeable future.

In Re PD · filed 1990-04-23(4)

In order to comply with the requirements of RCW 13.34.180(4), the State must affirmatively offer or provide the necessary services.

Section 13.34.180(4) requires the State to offer or provide reasonable and necessary services capable of correcting a parent's deficiencies within the foreseeable future; the services needed depend on the parent’s circumstances.

Davis v. Department of Social & Health Services · filed 1990-04-23(4)

Applying that rationale to the facts before us, we hold that the trial court correctly concluded that all reasonable and necessary services capable of correcting parental deficiencies were provided through Sandra's inpatient treatment at Western State Hospital.

Section 13.34.180(4) permits courts to consider services offered before dependency proceedings when deciding whether necessary services to correct parental deficiencies were offered.

Department of Social & Health Services v. Osborne-Tanner · filed 1990-10-29(4)

The consideration of any services offered prior to deprivation proceedings could be reasonably considered as bearing on the potential correction of parental deficiencies. The trial court did not err.

Section 13.34.180(4) requires the State to offer or provide reasonably available services capable of correcting parental deficiencies before terminating parental rights; services tailored to parents’ developmental disabilities can satisfy that requirement.

Robinson v. Department of Social & Health Services · filed 1995-06-20(4)

The Robinsons contend the State failed in its burden to prove that all the services "reasonably available” had been offered or provided. RCW 13.34.180(4). They argue that the services offered did not address their special needs as developmentally disabled parents. We disagree. The State provided services which were modified to accommodate the Robinsons’ specific disabilities.

Section 13.34.180(1)(d) requires DSHS to offer or provide reasonably available services capable of correcting parental deficiencies in the foreseeable future; it need not provide additional help with a program the parent fails to attend.

Department of Social & Health Services v. Hamm · filed 2005-05-16(1)(d)

DSHS provided all necessary services capable of correcting this parental deficiency in the foreseeable future. DSHS referred Hamm to two nonoffender treatment programs both of which Hamm was either unwilling or unable to make use of. DSHS was not required to assist Hamm with the third program after she missed the first two sessions.

Section 13.34.180(1)(d) requires DSHS to offer or provide services capable of correcting parental deficiencies in the foreseeable future, but does not require additional help when a parent is unwilling or unable to use services already offered.

In Re Dependency of SMH · filed 2005-07-06(1)(d)

DSHS provided all necessary services capable of correcting this parental deficiency in the foreseeable future. DSHS referred Hamm to two nonoffender treatment programs both of which Hamm was either unwilling or unable to make use of. DSHS was not required to assist Hamm with the third program after she missed the first two sessions.

Section 13.34.180(4) requires the State to show that ordered services were offered and that necessary, reasonably available services were offered or none were available.

In Re Dependency of JW · filed 1998-03-23(4)

Under RCW 13.34.180(4), the State must first prove that any services ordered at disposition have been offered. Here, the dispositional order relieved the State of this obligation. Nonetheless, the State still had to satisfy the court at termination that all necessary and reasonably available services capable of correcting parental deficiencies within the foreseeable future had been offered or alternatively that no such services were reasonably available.

Section 13.34.180(1)(d) does not require the State to offer placement with relatives as a service before terminating parental rights.

In Re Dependency of AA · filed 2001-04-02(1)(d)

The services to which RCW 13.34.180(1)(d) refers are those ordered under RCW 13.34.136. ... Placing the children with grandparents in Tennessee is more properly characterized as an "outcome" of the dependency proceedings, not as a service the State must offer while the dependency is going on.

Section 13.34.180(4) requires the state to offer or provide all reasonably available services capable of correcting parental deficiencies, including services suited to a parent's developmental disability.

Department of Social & Health Services v. Bissett · filed 1998-08-24(4)

Because the Department of Social and Health Services (DSHS) has not established by clear, cogent, and convincing evidence that it offered all reasonably available services capable of correcting parental deficiencies, we reverse and remand for further proceedings.

Section 13.34.180(1)(d) requires services ordered under section 13.34.136; placing children with relatives is an outcome of dependency proceedings, not a required service.

Aljic v. Department of Social & Health Services · filed 2001-04-02(1)(d)

The services to which RCW 13.34.180(l)(d) refers are those ordered under RCW 13.34.136. ... Placing the children with grandparents in Tennessee is more properly characterized as an “outcome” of the dependency proceedings, not as a service the State must offer while the dependency is going on.

Section 13.34.180(d) and (e) require a more stringent showing about remedial services and the prospects of returning the child to the parent than ICWA § 1912(d).

In Re Dependency of AM · filed 2001-05-07(d) and (e)

As we have noted, any difference in the requirements of § 1912(d) and RCW 13.34.180(d) and (e) are largely semantic; if anything, the showing required by our state statute is more stringent than that contained in § 1912(d).

Section 13.34.180 imposes a more stringent showing on remedial services than the ICWA’s active efforts provision.

Applebee v. Department of Social & Health Services · filed 2001-05-07(d), (e)

Moreover, to the extent that there may be anything more than a semantic difference in the requirements for remedial services under RCW 13.34.180 and ICWA, Washington’s statute places a more strenuous burden on the State than does § 1912(d).

The State must offer or provide necessary, reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re Dependency of TR · filed 2001-08-27(1)(d)

But the statute requires the State to prove only that it provided the services that were necessary, available, and capable of correcting parental deficiencies within the foreseeable future.

The State must provide necessary, reasonably available services capable of correcting parental deficiencies within the foreseeable future.

Department of Social & Health Services v. Rhyne · filed 2001-08-27(1)(d)

But the statute requires the State to prove only that it provided the services that were necessary, available, and capable of correcting parental deficiencies within the foreseeable future.

Section 13.34.180(1)(d) does not require referral to every specific agency when the parent has otherwise been offered the necessary services.

In Re Welfare of Angelo H. · filed 2004-12-09(1)(d)

Finally, Ms. H. contends the court erred by failing to refer her to S.L. Start and the Division of Developmental Disabilities. However, DSHS had referred Ms. H. to S.L. Start in a prior proceeding without success. In any event, this court has previously rejected a similar argument that failure to refer to specific agencies was sufficient to preclude a finding the requisite services had been offered under RCW 13.34.180(1)(d).

Section 13.34.180(1)(d) permits termination despite a failure to offer a service if that service would not have corrected the parent's deficiencies in the foreseeable future.

In Re Dependency of DA · filed 2004-12-13(1)(d)

Even where the State inexcusably fails to offer a service to a willing parent, termination is nonetheless appropriate if the service would not have remedied the parent's deficiencies in the foreseeable future.

The Department must offer or provide necessary services and cannot rely solely on others’ efforts if its own efforts might have succeeded.

Department of Social & Health Services v. C.A. · filed 2004-12-13(1)(d)

We emphasize, however, that the responsibility for offering or providing services belongs to the Department, and the Department cannot just point to the efforts of others if its own efforts might have succeeded where the others did not.

Section 13.34.180(1)(d) requires DSHS to offer all reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re Dependency of TLG · filed 2005-03-07(1)(d)

Here, given the protracted delay in obtaining the evaluations, and the false premise that all other services should await the examination results, DSHS failed to meet the requirements of RCW 13.34.180. The finding that all necessary services were offered is not supported by the record.

Section 13.34.180(1)(d) requires DSHS to offer all reasonably available services needed to correct parental deficiencies; it cannot delay those services while awaiting psychological evaluations.

Department of Social & Health Services v. Gilfillen · filed 2005-03-07(1)(d)

Here, given the protracted delay in obtaining the evaluations, and the false premise that all other services should await the examination results, DSHS failed to meet the requirements of RCW 13.34.180. The finding that all necessary services were offered is not supported by the record.

Section 13.34.180(1) permits termination despite a failure to offer services when those services could not remedy parental deficiencies within the child's foreseeable future.

In re the Welfare of C.L. · filed 2006-01-24(1)

A trial court has broad discretion to terminate parental rights if it finds the elements in RCW 13.34.180(1) are established by clear, cogent, and convincing evidence and termination is in the best interests of the child. ... Only one of these elements — that all necessary and reasonably available services capable of correcting the parenting deficiencies within the foreseeable future have been offered and provided — is at issue here. ... Because services would not have remedied deficiencies in the foreseeable future, the court properly terminated Mr. Eubanks’s parental rights.

Section 13.34.180(1)(d)'s services requirement cannot support termination unless the State first shows a parental deficiency that services could correct.

In Re SG · filed 2007-08-30(1)(d)

But the more basic problem is that it is impossible to evaluate the sufficiency or efficacy of services as to Mr. Gallardo-Cruz when, at this point, the State failed to show he required any. Without a problem, there can be no solution.

Subsection (1)(e) requires evidence that parental deficiencies are unlikely to be remedied in the near future; a mental health condition must be shown to affect parenting before it can count as a deficiency.

In Re Welfare of Ag · filed 2010-04-20(1)(e)

The evidence then does not support a finding that Ms. G.'s mental health issues interfere with her ability to parent these children. RCW 13.34.180(1)(e). ¶ 35 But the evidence here supports the court's findings on both substance abuse and domestic violence. And those findings, in turn, support the statutorily mandated requirement of parental deficiencies that will not be resolved within the near future.

Section 13.34.180(1)(d) permits termination despite a failure to offer necessary services when the evidence shows those services would not remedy parental deficiencies in the foreseeable future.

Dependency Of P.s.f. Atiba Fleming v. Dshs · filed 2013-07-22(1)(d)

The Department's failure to offer or provide the necessary services notwithstanding, termination may still be appropriate if there is evidence in the record from which the trial court could have concluded that such services would not have remedied parental deficiencies "in the 'foreseeable future.'" Hall, 99 Wn.2d at 851 (quoting former RCW 13.34.180(4) (1979)) (this section has been renumbered at RCW 13.34.180(1 )(d)).

Section 13.34.180(1)(d) requires services capable of correcting parental deficiencies; visitation alone is not such a service.

In Re Dependency of TH · filed 2007-07-23(1)(d)

There may be situations where visitation is part of a required service, such as an interactive parenting class. But it does not, on its own, correct parental deficiencies to enable the parent to resume custody, and thus, we conclude that it is not a "service" that must be provided under RCW 13.34.180(1)(d).

Visitation alone is not a service that must be provided to correct parental deficiencies before termination.

Department of Social & Health Services v. Hackney-Farias · filed 2007-07-23(1)(d)

There may be situations where visitation is part of a required service, such as an interactive parenting class. But it does not, on its own, correct parental deficiencies to enable the parent to resume custody, and thus, we conclude that it is not a “service” that must be provided under RCW 13.34.180(l)(d).

Section 13.34.180(1)(d) does not treat visitation as a service the Department must offer to satisfy the service requirement for termination.

In Re The Dependency Of: S.c.p., Lorraine R. Payton, App. v. State, Dshs, Res. · filed 2013-05-20(1)(d)

Further, the amendment to the federal statute does not, as Reyes argues, change our holding in In re Dependency of T.H. that visitation is not a "service" for purposes of RCW 13.34.136 and 13.34.180(1 )(d).

Section 13.34.180(1)(d) requires a finding of parental deficiencies before a court can assess whether services were sufficient to correct them.

Department of Social & Health Services v. Gallardo-Cruz · filed 2007-08-30(1)(d)

The availability of rehabilitative services is irrelevant to a parent who has not been found to have parental deficiencies. This statutory factor assumes that such a finding has already been made prior to the hearing for termination and for good reason — the parental rights of a fit parent cannot be terminated.

The Department satisfied subsection (1)(d) by expressly and understandably offering the necessary services.

Department of Social & Health Services v. Luak · filed 2012-03-01(1)(d)

Judge Doerty heard the evidence from both sides and specifically concluded that necessary services had been understandably, expressly, and repeatedly offered. Substantial evidence supports his conclusion.

The Department satisfies subsection (1)(d)'s services requirement when it offers services and the parent refuses to participate.

In re the Welfare of M.R.H. · filed 2008-03-25(1)(d)

Where the Department offers services but the parent refuses to participate, RCW 13.34.180(l)(d) is satisfied.

Section 13.34.180 requires the State to offer or provide reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re Dep Of: G.g. Dob: 12/19/02 Joel Garcia App. v. Dshs, Resp. · filed 2013-04-29

Substantial evidence supports the trial court's determination that all reasonably available services, capable of correcting the identified parental deficiencies within the foreseeable future, were expressly and understandably offered or provided to Garcia.

Section 13.34.180(1)(d) does not require the Department to offer additional services when a parent is unable to make use of services already provided.

Dependency Of: B.m.a.o., 8/3/08, Dshs v. Ostrander · filed 2013-04-29(1)(d)

Ostrander's inability to follow through with existing services excused the Department from offering additional services, even assuming they were necessary, reasonably available, and capable of correcting Ostrander's parental deficiencies within the foreseeable future. TJ^, 108 Wn. App. at 163. His challenge to the trial court's finding under RCW 13.34.180(1 )(d) fails for this additional reason.

Section 13.34.180(1)(d) requires the State to offer necessary services to address a condition preventing reunification, even if the condition is not labeled a parental deficiency.

In Re Welfare of Cs · filed 2010-01-21(1)(d)

When a "condition" precludes reunion of parent and child, as here, regardless of whether it can be labeled a "parental deficiency," the State must provide any necessary services to address that condition as set forth in RCW 13.34.180(1)(d).

Section 13.34.180(1)(d) does not require the State to offer additional services when a parent is unwilling or unable to use the services already provided.

In Re Welfare of Lnb-L · filed 2010-06-29(1)(d)

A parent's unwillingness or inability to make use of the services provided excuses the State from offering extra services that might have been helpful.

Section 13.34.180(1)(d) requires the Department to offer or provide necessary services reasonably available to correct parental deficiencies.

In Re Welfare of LNB-L. · filed 2010-08-03(1)(d)

Both JB-L and KL assign error to finding VIII, which addresses the second sentence of RCW 13.34.180(1)(d). ... Substantial evidence exists that the Department offered both JB-L and KL all necessary services to correct their parental deficiencies.

Section 13.34.180(1)(d) requires the State to offer or provide necessary services tailored to each parent's needs and capable of correcting parental deficiencies within the foreseeable future.

In Re SJ · filed 2011-08-02(1)(d)

The termination statute requires the State to prove DSHS "offered or provided all and necessary services, reasonably available, capable of correcting the parental deficiencies." RCW 13.34.180(1)(d). To meet this statutory burden, the State must tailor the services it offers to meet each individual parent's needs. ... TH was not provided attachment and bonding services for her and SJ even though the State acknowledged her need. We cannot say the services would have been futile. ... The trial court erred in finding that all necessary services had been provided.

The State must tailor necessary services to a parent’s needs and offer or provide reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In re the Welfare of S.J. · filed 2011-08-02(1)(d)

The termination statute requires the State to prove DSHS “offered or provided ... all and necessary services, reasonably available, capable of correcting the parental deficiencies.” RCW 13.34.180(l)(d). To meet this statutory burden, the State must tailor the services it offers to meet each individual parent’s needs.

Section 13.34.180(1)(d) excuses a failure to offer necessary services when offering them would be futile.

In re the Welfare of J.B. · filed 2013-03-28(1)(d)

The failure to offer necessary services is excusable if the effort would be futile.

Section 13.34.180(1)(d) requires the Department to offer court-ordered services and reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re The Dependency Of: A.u.n.h. Carey Hayes, App. v. State Of Wa., Dshs, Res. · filed 2013-07-29(1)(d)

Thus, the statute requires that the Department must offer the services expressly ordered by the trial court and that the Department provide other necessary services, reasonably available, which would correct the parental deficiencies.

The Department met its duty to offer or provide necessary, reasonably available services capable of correcting the parent’s deficiencies.

In Re The Dependency Of F.k.o. Lindsey Oldham v. Dshs · filed 2013-07-29(1)(d)

Accordingly, clear and convincing evidence supported the trial court's finding that the Department met its obligations with regard to offering or providing all necessary, reasonably available services, capable of correcting Oldham's parental deficiencies.

The Department met subsection (1)(d)’s service requirement despite the parent’s argument that more services were needed.

Dependency Of K.l.g., 11/22/95, Dshs v. Grayson · filed 2013-08-05(1)(d)

As such, we reject Grayson's argument that the Department failed to offer or provide her with services able to correct her parental deficiencies in the foreseeable future.

Section 13.34.180(1)(d) does not bar termination when an omitted service would not remedy the parent's other deficiencies within the children's foreseeable future.

In Re The Dep Of T.m.d., D. Jones v. Dshs State Of Washington · filed 2013-09-23(1)(d)

This is sufficient for us to conclude that the failure to provide parenting classes specifically tailored for T.M.D.'s and T.T.D.'s special needs is not a bar to termination. Those classes would not have remedied Jones's other deficiencies.

Suspended contact made interactive therapeutic parenting skills training unavailable to the parent.

Dependency Of A.n.s., B.d. 03/13/09, Dshs, Resp v. Michelle Spruel, App · filed 2014-07-21(1)(d)

Because Spruel was not permitted to have contact with A.N.S., even if Spruel had familiarized herself with the pertinent literature the fact remained that therapeutic parenting skills—which, by definition, require an interactive component—were not available to her.

Section 13.34.180(d) requires the State to offer or provide necessary and reasonably available services; a psychiatric evaluation is not required without evidence that it is a necessary service.

Dep Of M.n., Rachel Niehaus v. Dshs State Of Washington · filed 2014-07-28(d)

The record does not establish that a psychiatric evaluation of Niehaus's PTSD medication was a necessary service. The trial court did not err infinding that all necessary and reasonably available services were provided to Niehaus.

The Department satisfied subsection (1)(d)’s necessary-services requirement.

In Re The Dep Of G.c., Andrea Cerio, App v. Dshs State Of Washington · filed 2014-08-11(1)(d)

Also, substantial evidence supports the trial court's finding that the Department met the requirements of RCW 13.34.180(1 )(d).

Section 13.34.180(1)(d) requires proof that necessary services were offered or provided; ordering services alone does not establish that they were offered.

In re the Dependency of: E.W. · filed 2014-10-21(1)(d)

We agree with K.A.S. that the record does not support the finding that these services were "offered or provided."

Section 13.34.180(1)(d) allows a court to find that all reasonable services were offered when an additional service would have been futile because it could not remedy parental deficiencies in the foreseeable future.

In Re The Dependency Of E.m.m.t. Kenyaghta Thornton, App. v. State Of Wa., Dshs, Res. · filed 2015-01-20(1)(d)

Thus, if the record establishes that offering a service would have been futile, the trial court can make a finding that the State offered all reasonable services. ... The record in this case amply demonstrates that a separate referral for domestic violence treatment would not have remedied Kenyaghta's parental deficiencies in the foreseeable future and would have been futile.

The State satisfies the services requirement when it offers or provides reasonably available services capable of correcting parental deficiencies; it need not provide a child's proposed therapy absent evidence that it would help correct those deficiencies.

In Re The Dependency Of D.r. Lan Tran v. Dshs · filed 2015-03-09(1)(d)

Given the undisputed severity of Tran's parental deficiencies and her failure to make any meaningful progress despite four years of services, nothing in the record supports an inference that FR's and DnR's participation in TFCBT would have facilitated Tran in correcting her parental deficiencies. Substantial evidence supports the trial court's determination that all services reasonably available and capable of correcting Tran's parental deficiencies were offered or provided.

Section 13.34.180(1)(d) requires the State to expressly and understandably offer or provide necessary services capable of correcting parental deficiencies in the foreseeable future.

In Re Dep Of: L.b.s.p., Dob: 7/17/12 Trina Curry, App. v. Dshs, Resp. · filed 2015-06-08(1)(d)

Under these circumstances, the record supports the court's findings that the Department expressly and understandably offered the mental health services Curry needed to address her parental deficiencies but she failed to avail herself of the services offered.

Section 13.34.180(1)(d) requires DSHS to expressly and understandably offer or provide necessary services, but does not entitle a parent to services from a preferred provider.

In re the Interest of: S. W. · filed 2015-10-08(1)(d)

The statute merely requires DSHS to "expressly and understandably" offer or provide the necessary services. RCW 13.34.l80(1)(d). DSHS did that here with its referral to STOP, an approved provider. Nothing in the statute entitles G.W. to require DSHS to pay for equivalent services with his preferred provider.

Visitation alone is not a service the Department must provide under § 13.34.180(1)(d) because it does not itself correct parental deficiencies.

Dep Of T.m.s., Rebekka Mccray, App v. Dshs, State Of Washington · filed 2013-10-07(1)(d)

And despite her argument, visitation "does not, on its own, correct parental deficiencies to enable the parent to resume custody, and thus, ... it is not a 'service' that must be provided under RCW 13.34.180(1 )(d)."

Section 13.34.180(1)(d) requires necessary services capable of correcting parental deficiencies to be offered or provided; visitation alone is not a required service.

In re the Dependency of: O.R.L. · filed 2015-03-24(1)(d)

We reaffirm In re Dependency of T.H., 139 Wn. App. 784, 162 P.3d 1141 (2007), hold that visitation is not a required service, and affirm the trial court's order terminating Ms. Lewis's parental rights to O.R.L.

When cognitive impairment causes parenting deficiencies, the court must assess whether those deficiencies can be remedied and whether services can remedy them.

Department of Social & Health Services v. E.I. · filed 2014-04-01(1)(d), (e)

In other words, the proper inquiry for the juvenile court is whether the parenting deficiencies resulting from cognitive impairments can be remedied and whether services can be offered or provided that may remedy the parenting deficiencies.

Section 13.34.180(1)(d) requires the Department to offer or provide necessary, reasonably available services capable of correcting parental deficiencies within the foreseeable future, whether or not a court ordered them.

Dependency Of E.s., 05/18/03, Dshs, Resp v. Jason Scott, App · filed 2014-11-17(1)(d)

It is well settled that RCW 13.34.180(1)(d) requires the Department to offer or provide all necessary services, whether court- ordered or not, that are "reasonably available" and "capable of correcting the parental deficiencies within the foreseeable future." Nothing in the statute requires that the services the Department must offer be set forth in a court order.

Section 13.34.180(1)(d) does not require the State to provide further services when they would be futile or could not correct parental deficiencies within the foreseeable future.

Dependency Of C.t. Karina Torrescano-hernandez v. Dshs · filed 2015-09-28(1)(d)

But the State does not have to provide services where to do so would be futile, or where a parent is unwilling or unable to take advantage of those services. ... The State satisfied the requirements of RCW 13.34.180(1 )(d).

Section 13.34.180(1)(d) requires the State to offer or provide necessary, reasonably available services to correct parental deficiencies.

In re the Welfare of: A.K.J.M.W. · filed 2015-04-23(1)(d)

Thus, substantial evidence supports the trial court's finding that DSHS offered all reasonably available, necessary services in an attempt to correct the mother's parental deficiencies.

Section 13.34.180(1)(d)'s services requirement is satisfied when the Department offers services but the parent refuses to participate.

In Re The Dep Of T.s., Willie Mathews v. Dshs State Of Washington · filed 2015-07-20(1)(d)

Where, as here, the Department offers services "but the parent refuses to participate, RCW 13.34.180(1)(d) is satisfied."

Section 13.34.180(1)(d) does not treat visitation as a service the Department must provide to prove that it offered all necessary services.

In re the Parental Rights to K.M.M. · filed 2015-05-05(1)(d)

Visitation is not a service for the purpose of determining whether the Department met its burden to prove that all necessary services, reasonably available, capable of remedying parental deficiencies were expressly and understandably offered or provided under RCW 13.34.180(l)(d).

Section 13.34.180 does not require a termination petition to specify every alleged parental deficiency, although the parent must receive notice of the deficiencies before termination.

In re the Termination of: F. M. O. · filed 2016-05-24

Accordingly, we decline S.O.'s request to mandate that ... parental deficiencies be specified in the termination petition.

Section 13.34.180(1)(d) does not require the State to offer an additional corrective service when a parent fails to participate in closely related services already offered.

In re the Welfare of: R. H. · filed 2015-10-28(1)(d)

The State was not required to offer an additional service when S.H. was continually failing to participate in two closely related services.

Section 13.34.180(1)(d) does not require DSHS to offer additional services when the parent's lack of engagement would make them futile.

Dependency Of C.e.t., A.k.a. C.e.f., B.d. 8/26/13, Roger Tolbert v. Dshs · filed 2015-11-23(1)(d)

It would have been futile to offer Tolbert additional services at the time, and DSHS was not obligated to do so.

Section 13.34.180(1)(d) requires the Department to offer or provide necessary services capable of correcting parental deficiencies in the foreseeable future, but does not require services that would be futile.

In Re the Parental Rights to R.M.P. · filed 2015-12-15(1)(d)

We conclude that sufficient evidence supports the trial court's determination that the Department showed by clear, cogent, and convincing evidence that it offered or provided all necessary services to S.S.B., and that the additional services testified to by Dr. Page would have been futile.

Section 13.34.180(1)(d) requires the Department to offer or provide all court-ordered services and reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re The Dep. Of: E.j.l., Carrie Lehnert, App. v. Dept. Of Social & Health Services, Resp. · filed 2016-02-29(1)(d)

Under RCW 13.34.180(1 )(d), the Department must prove that it offered or provided all court-ordered services and "all necessary services, reasonably available, capable of correcting the parental deficiencies within the foreseeable future." ... Substantial evidence supports the trial court's finding that an updated psychological evaluation was not a necessary service and that the Pepartment offered or provided Lehnert with all necessary services capable of correcting parental deficiencies within the foreseeable future.

The Department was not required to provide additional services under subsection (1)(d).

In re the Welfare of: D. B. · filed 2016-03-01(1)(d)

Thus, the Department was not required to provide additional services.

The Department satisfied subsection (1)(d) by offering necessary services to address the parent’s mental health concerns.

In Re The Dependency Of: A.b. Erika Yrizarris, App. v. State Of Wa., Dshs, Res. · filed 2016-03-14(1)(d)

Here, substantial evidence supports the finding that DSHS offered all necessary and appropriate services to address Yrizarris' mental health concerns.

Section 13.34.180(1)(d) requires the State to expressly and understandably offer or provide court-ordered services and reasonably available services capable of correcting parental deficiencies in the foreseeable future.

In re the Termination of: F. H. · filed 2016-05-24(1)(d)

Substantial evidence supports the trial court's finding that all services, court ordered or otherwise necessary, reasonably available, and capable of correcting the mother's parental deficiencies in the foreseeable future were expressly and understandably offered or provided.

Section 13.34.180(1)(d) requires the State to provide available services needed for reunification before terminating parental rights, unless those services would be futile.

In re Welfare of B.P. · filed 2016-07-28(1)(d)

Absent a showing of futility, H.O. was entitled to any available services necessary to facilitate reunification with B.P. It was not her burden to prove that these services would succeed before the State provided them.

Section 13.34.180(1)(d) requires the State to offer or provide reasonably available services that could correct parental deficiencies before terminating parental rights; services are not futile merely because success is uncertain.

Department of Social & Health Services v. H.O. · filed 2016-07-28(1)(d)

Thus, the State did not fulfill its obligation to provide “all necessary services, reasonably available, capable of correcting the parental deficiencies within the foreseeable future,” RCW 13.34.180(1)(d), and the termination order must be reversed.

Section 13.34.180(1)(d) does not require the Department to give noncustodial parents the same services it gives foster parents.

In re Parental Rights to K.M.M. · filed 2016-09-08(1)(d)

While the fact that foster parents receive certain services may be evidence of reasonable availability, it does not create an inflexible requirement that noncustodial parents receive identical services.

The Department satisfied subsection (1)(d) by timely offering or providing the necessary services.

In Re The Dependency Of: E.a.s., Dob: 9/16/03., Christiana Ostrander v. Dshs · filed 2016-10-03(1)(d)

Substantial evidence supports the finding that the Department timely offered or provided all necessary services capable of correcting the mother's parental deficiencies but she failed to successfully complete drug treatment and other services offered.

Section 13.34.180(1)(d) requires bonding and attachment therapy as a necessary service when the lack of bonding prevents reunification.

In re the Termination of K. S. F. · filed 2016-11-01(1)(d)

Thus, in determining whether bonding and attachment therapy was a necessary service under RCW 13.34.180(l)(d), the central question is whether this lack of bonding and attachment prevented Mr. F. and K.S.F. from reunifying. If it did, it was a necessary service.

Section 13.34.180(1)(d) requires the Department to offer all reasonably available services needed to correct parental deficiencies and to tailor those services to the parent's needs.

In re the Termination of: IM.- M. & Z.M. - M. · filed 2016-12-01(1)(d)

By statute, the Department was required to offer C.M. "all necessary services, reasonably available, capable of correcting the parental deficiencies within the foreseeable future." RCW 13.34.180(l)(d). ... Further, the Department must tailor the services offered ... to the individual's needs. ... The trial court's finding that C.M. was offered all necessary services is not supported by substantial evidence.

Drug treatment was not a necessary service under subsection (1)(d) in this case.

In re the Termination of El.g. · filed 2016-12-20(1)(d)

Drug treatment was never a necessary service in this case.

Section 13.34.180(1)(d) does not require visitation as a service because visitation alone does not correct parental deficiencies.

In Re The Dependency Of: J.a.p., D.o.b. 3/31/07 David Perry v. Dshs · filed 2015-11-23(1)(d)

But, as the court properly found, while undoubtedly crucial for reunification, visitation does not, on its own, correct parental deficiencies and is not a "service" that must be provided under RCW 13.34.180(1)(d).

Section 13.34.180(1)(d) requires the Department to offer necessary services capable of correcting parental deficiencies; visitation alone is not a required remedial service.

In re the Dependency of: O.R.L. · filed 2015-12-08(1)(d)

While visitation was offered to K.L., it was not a required remedial service. ... The Department established all of the required statutory elements of RCW 13.34.180. Specifically, the Department offered or provided all reasonably necessary services capable of correcting K.L.'s parental deficiencies.

Section 13.34.180(1)(d) does not require the Department to provide or offer visitation as a necessary service before terminating parental rights.

In Re The Dependency Of C. G. R. Aundrea Kopp v. Dshs · filed 2016-06-27(1)(d)

Here, visitation is not a service that must be provided or offered.

Section 13.34.180(1)(d) requires the State to offer or provide all court-ordered and necessary services, including services tailored to the parent's needs.

In re the Termination of: J. L. Q.-R. · filed 2016-05-05(1)(d)

The undisputed evidence supports the conclusion that the State breached these obligations to provide services. In short, the State failed to prove compliance with RCW 13 .34.180( 1)( d) by clear, cogent, and convincing evidence.

Section 13.34.180(1)(d) does not require the Department to take unreasonable steps to tailor services when a parent is unwilling to engage in them.

In re the Welfare of: M.A. · filed 2016-05-24(1)(d)

As with the other services, RCW 13 .34.180(1 )( d) did not require the Department to go to unreasonable lengths to tailor the services it offered when J.V. was unwilling to engage in them.

Section 13.34.180(1)(d) requires ordered and necessary services to be expressly and understandably offered or provided; counseling recommended under a dispositional order is a court-ordered service.

Dependency Of: J.r.p.m., 11/6/12, Dshs v. Mcbride · filed 2016-07-25(1)(d)

But as previously noted, the disposition order plainly required any counseling recommended by Dr. Tutty. Thus, his counseling recommendation was a court-ordered service and service letters referring to it as such were correct.

Section 13.34.180(1)(d) requires the Department to offer or provide all necessary, reasonably available services capable of correcting a parent's deficiencies.

In Re The Dependency Of J.t.r., Abigail Rocco, App v. Dshs State Of Washington · filed 2016-11-14(1)(d)

Rocco contends that the Department failed to prove it offered or provided her with all necessary services capable of correcting her parental deficiencies as required ... by RCW 13.34.180(1)(d). ... Clear, cogent, and convincing evidence supports the court's determination that the Department offered or provided all necessary services capable of correcting her parental deficiencies.

The Department satisfied subsection (1)(d) by offering necessary services to address the parent’s substance abuse.

In Re The Dependency Of J.o., 10/17/13, Sonia Orozco-salgado v. Dshs · filed 2017-01-09(1)(d)

Substantial evidence supports the trial court's finding that the Department offered or provided all necessary and appropriate services to address Orozco's substance abuse problems as required by RCW 13.34.180(d)(1).

Section 13.34.180(1)(d) requires the Department to offer or provide all necessary, reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re The Dependency Of C.j.f., 03/22/03, Jake Fair v. Dshs · filed 2017-01-23(1)(d)

Here, substantial evidence supports the trial court's finding that all necessary and reasonably available services were offered to the parents.

Section 13.34.180(1)(d) requires DSHS to offer or provide necessary services tailored to the parent's needs.

In re the Welfare Of: A.H. · filed 2017-12-14(1)(d)

The trial court found she was reasonably offered this service in a tailored fashion, and substantial evidence supports this finding.

Section 13.34.180(1)(d) requires the State to offer or provide services capable of correcting parental deficiencies, but a failure to arrange services may be excused when doing so would be futile.

In re the Parental Rights to: D.W.T. · filed 2018-06-07(1)(d)

We may also criticize later social worker Heather Schrader for failing to aggressively contact Tresh while imprisoned and failing to arrange for services ... immediately on Tresh’s release from prison in April 2016. We find this failure, however, excusable since Tresh failed to participate in any services once DCFS arranged for services. Clear, cogent and convincing evidence established the futility of scheduling services.

Section 13.34.180(1)(d) requires the department to offer or provide necessary, reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re The Dependency Of S.m.m. Angela Waldo, App. v. State Of Wa., Dshs, Res. · filed 2018-07-23(1)(d)

Here, substantial evidence in the record supports the trial court's finding that dialectical behavioral therapy was offered or provided to Waldo.

The Department satisfies the necessary services requirement when additional services would be futile to correct the parent's deficiencies within the foreseeable future.

In Re The Terminiation Of: B.m.c. William Chambers v. Dshs · filed 2017-01-23(1)(d)

Accordingly, sufficient evidence supports the trial court's finding that the Department offered or provided all necessary services as required by RCW 13.34.180(1 )(d) because any additional services would have been futile.

Section 13.34.180(1)(d) requires the Department to offer or provide all necessary, reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re The Dependency Of Enm, Bertram Mackey v. Dshs · filed 2017-02-27(1)(d)

Substantial evidence supported the trial court's findings that Alvy's treatment was as effective as possible under the circumstances and that the Department provided all ... necessary services capable of correcting Mackey's parental deficiencies within the foreseeable future.

The Department satisfies the necessary reunification services requirement by providing services tailored to a parent's core deficiencies; it need not provide services that would not remedy them.

In re the Termination of: Na.W. and No.W. · filed 2017-02-28(1)(d)

By providing A. W. mental health counseling, targeted at his individual needs, the Department offered all reasonably necessary services.

Section 13.34.180(1)(d)'s necessary services requirement may be satisfied when equivalent services were provided and additional evaluation and treatment would have been futile.

In Re The Dependency Of: C.l.m. Latae Maria Mitchell, App. v. State Of Wa., Dshs, Res. · filed 2017-03-13(1)(d)

Substantial evidence supports the court finding that any additional evaluation and treatment would have been futile.

Section 13.34.180(1)(d) requires services that address a condition preventing reunification; services aimed at impending reunification are unnecessary when the parent has not approached that point.

Dep Of Ab., Mattie Macarthur v. Dshs State Of Washington · filed 2017-03-27(1)(d)

A service is "necessary" within the meaning of RCW 13.34.180(1)(d) if it is "needed to address a condition that precludes reunification of the parent and child." ... We conclude that neither PCIT nor FPS was a necessary service under the facts of this case.

Under subsection (1)(d), a delay in providing necessary services does not prevent termination when earlier provision would have been futile and would not have remedied parental deficiencies in the foreseeable future.

In Re The Termination Of: N.f.w. Nicole E. Woods, App. v. State Of Wa., Dshs, Res. · filed 2017-04-24(1)(d)

In these circumstances, earlier provision of the services recommended by Dr. Shepel would have been futile and would not have remedied Woods' parental deficiencies within the foreseeable future.

The Department may satisfy the requirement to offer necessary services when an unoffered service would have been futile.

Dependency Of D.f.-s. Lo Saelee v. Dshs · filed 2017-10-02(1)(d)

This means that when the record establishes that an offer of services would have been futile, the trial court can make a finding that the Department has offered all reasonable services.

Section 13.34.180(1)(d) requires DSHS to expressly and understandably offer or provide reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re The Welfare Of D.m.m. · filed 2017-10-10(1)(d)

Under RCW 13.34.180(1)(d), the DSHS must prove “[t]hat the services ordered under RCW 13.34.136 have been expressly and understandably offered or provided and all necessary services, reasonably available, capable of correcting the parental deficiencies within the foreseeable future have been expressly and understandably offered or provided.” ... We hold that the juvenile court properly concluded that all reasonable services had been offered or provided.

Section 13.34.180(1)(d) requires DSHS to offer or provide necessary services capable of correcting parental deficiencies, but does not require services that would be futile.

In re the Parental Rights to: T.T. · filed 2017-11-09(1)(d)

Accordingly, the trial court's findings that Mr. T. was offered or provided services for anger management and chemical dependency treatment, and that any additional services would have been futile, are supported by substantial evidence.

Section 13.34.180(1)(d) requires the Department to expressly and understandably offer or provide necessary, reasonably available services capable of correcting parental deficiencies.

In The Matter Of The Dep. Of: A.a., Dob: 2/4/15, Andre Ash v. Dshs · filed 2017-12-18(1)(d)

This substantial evidence adequately supports the trial court finding that the Department offered Ash all necessary services following his conviction.

Section 13.34.180(1)(d) does not require additional housing services when there are no reasonable grounds to believe they would correct the parent's deficiencies.

In Re Dependency Of: M.k.g.p., Dob: 4/14/14, Fauniteni Pauni Jr., App v. Dshs, Resp · filed 2018-01-16(1)(d)

Under these circumstances, there are no reasonable grounds to believe that additional housing services would have remedied Pauni's parental deficits. Substantial evidence supports finding the Department timely offered or provided all necessary services capable of correcting Pauni's parental deficiencies.

Subsection (1)(d)'s necessary services requirement can be satisfied by reasonable efforts to persuade a parent to accept services when the parent refuses them.

In Re The Dep Of Dmr., Cleve A. Goheen-rengo, App v. Dshs State Of Wa. · filed 2018-03-05(1)(d)

Given the nature of Carey's mental health issues, the Department's approach and efforts were reasonable. ... Substantial evidence supports the finding that the Department offered or provided Carey all necessary services under RCW 13.34.180(1)(d).

Section 13.34.180(1)(d) is satisfied when the State offers necessary services, even if the parent refuses them.

In re the Parental Rights to: P.L.F. · filed 2018-03-15(1)(d)

Each time Sargent refused the offer for the service she now alleges as necessary. Offering of services suffices.

Section 13.34.180(1)(d) requires the Department to offer or provide reasonably available services tailored to the parent's needs and capable of correcting parental deficiencies within the foreseeable future.

In Re The Dependency Of: S.i., Vanla Inthiranthvongsy v. Dshs · filed 2018-04-23(1)(d)

Substantial evidence establishes that the Department offered or provided all necessary and reasonably available services capable of correcting parental deficiencies within the foreseeable future in accordance with RCW 13.34.180(1)(d).

Section 13.34.180(1)(d) requires the Department to offer or provide all reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re The Dependency Of M-a.f-s. · filed 2018-04-30(1)(d)

Substantial evidence establishes the Department proved it offered or provided all reasonably available services capable of correcting parental deficiencies within the foreseeable future under RCW 13.34.180(1)(d).

Section 13.34.180(1)(d) requires the Department to expressly and understandably offer ordered services and reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re Dependency Of F.p.s., 9/22/08, Fidel Padilla-negrete, App v. Dshs, Resp · filed 2018-05-14(1)(d)

The extensive services were expressly and understandably offered to both Smith and Padilla-Negrete. The Department proved this requirement of RCW 13.34.180 by clear, cogent, and convincing evidence.

Section 13.34.180(1)(d) requires the State to offer necessary, reasonably available services capable of correcting parental deficiencies; an evaluation used to identify treatment is not itself a necessary service.

In Re The Dependency Of J.a.j., Patricia Dimitry v. Dshs · filed 2018-06-25(1)(d)

As Dimitry acknowledges, the purpose of the evaluation itself was not to enable reunification, but to direct her toward appropriate services. The mental health treatment that followed from the evaluation, not the evaluation itself, was the service necessary to address a condition precluding reunification.

Section 13.34.180(1)(d) requires the State to offer or provide all necessary, reasonably available services capable of correcting parental deficiencies within the foreseeable future.

In Re The Dep Of D.w.n., Michell Nations v. Dshs · filed 2017-01-23(1)(d)

To terminate parental rights, the State must prove that it offered all necessary services capable of correcting the specific parental deficiencies within the foreseeable future. RCW 13.34.180(1)(d). ... Clear, cogent, and convincing ... evidence supports the court's determination that the Department offered or provided to Nations all necessary services capable of correcting her parental deficiencies.

The court rejected requests for services never ordered in the dependency action under subsection (1)(d).

In re the Parental Rights to: Z.K.F. · filed 2017-10-26(1)(d)

RCW 13 .34.180(1 )( d) only applies to services ordered by the trial court in the dependency action.

Section 13.34.180(1)(d) requires the Department to offer necessary services early enough for a parent to demonstrate progress before a termination trial when earlier services could have corrected the parental deficiencies.

In re the Termination of A.M.S. · filed 2017-02-07(1)(d)

RCW 13 .34.180( d) does not literally require the Department to "timely" offer necessary services. But it does limit necessary services to those "capable of correcting the parental deficiencies within the foreseeable future." And RCW 13 .34.180( 1)( e) authorizes the termination of parental rights where "there is little likelihood that conditions will be remedied so that the child can be returned to the parent in the near future." So timeliness matters where it can be shown that early services could have corrected parental deficiencies or remedied conditions in time for the child to be returned, but the Department offered services too late for the parent to demonstrate correction and remediation at the termination trial.

Section 13.34.180(1)(d) requires the Department to expressly and understandably offer or provide necessary services capable of correcting parental deficiencies within the foreseeable future.

In Re The Dependency Of L.r.: Laquisha Reed, App. v. State Of Wa., Dshs, Res. · filed 2017-07-31(1)(d)

The record supports the court's finding and conclusion that DBT was expressly and understandably offered or provided as required by RCW 13.34.180(1)(d).

Section 13.34.180(1)(d) does not require a service that cannot correct parental deficiencies within the children’s foreseeable future.

In Re The Dependency Of: A.d.r. Reina Rife v. Dshs · filed 2017-02-13(1)(d)

We conclude that completing the parent-child observation was not a service capable of correcting Danny’s parental deficiencies within the children’s foreseeable future. When the record establishes that the offer of services would be futile, the trial court does not err in finding that the Department has met the services requirement.

Section 13.34.180(1)(d) requires the Department to offer reasonably available services that could address a parent's deficiencies within the foreseeable future, but does not require services that would be futile.

In re the Parental Rights to: E.J.E.G. · filed 2017-09-28(1)(d)

At a proceeding terminating parental rights, the Department is tasked with proving by clear, cogent and convincing evidence that it has offered a parent all reasonably available services capable of addressing parenting deficiencies within the foreseeable future. RCW 13.34.180(l)(d), .190(l)(a)(i). But the Department is not obliged to prove it offered services that would have been futile. ... The record here overwhelmingly supports a finding of futility. ... The trial court had substantial evidence to find the Department established the requirements for termination under RCW 13.34.180(1).

Section 13.34.180(1)(d) requires the Department to offer or provide court-ordered services; offering a parenting class satisfies that duty when the parent chooses coaching instead.

In Re Dependency Of: S.t., Dob: 03/25/04., Dshs v. Tangalan · filed 2018-02-26(1)(d)

First, the record demonstrates that the Department offered a parenting class, but Tangalan simply wanted a parenting coach instead. Thus, the Department fulfilled its duty to offer or provide court-ordered services under RCW 13.34.180(1)(d).

Visitation is not a service the Department must provide to satisfy the termination requirement in subsection (1)(d).

Dependency Of C.d.s., B.d. 11/6/11, Jason Michael Abrahamson, App v. Dshs, Resp · filed 2018-02-26(1)(d)

Although visitation is not a service for purposes of satisfying RCW 13.34.180(1)(d), substantial evidence nonetheless supports the juvenile court's finding that the social worker made reasonable efforts to facilitate visitation.

Visitation alone is not a service the Department must offer to meet its burden under section 13.34.180(1)(d).

In Re The Dependency Of R.m.r., Gerald Gotcher, App v. Dshs, Resp · filed 2018-07-23(1)(d)

First, Gotcher's claim that the Department was required to facilitate visitation fails because, while undeniably important for reunification, it is well settled that visitation is not a service for the purposes of proving RCW 13.34.180(1)(d).

The Department bears the burden of proving that it offered or provided all necessary, reasonably available services; a parent's opportunity to request services does not shift that burden.

In Re The Dependency Of: T.m.p-s., Lisa Danielle Purcell v. Dshs · filed 2018-03-12(1)(d)

In fact, the trial court was well aware that the Department bore the burden of proof to show that all services had been provided. The challenged finding simply establishes that there was no evidence of available services that had not been provided. This was not error.

Section 13.34.180(1)(d) requires the Department to offer or provide all necessary, reasonably available services capable of correcting parental deficiencies within the foreseeable future.

Dependency Of K.o. · filed 2018-09-17(1)(d)

Substantial evidence supports the trial court's finding that the Department offered or provided all necessary and reasonably available services capable of correcting parental deficiencies within the foreseeable future in accordance with RCW 13.34.180(1)(d).

The Department need not provide additional housing assistance when it would be futile and would not remedy the parent's deficiencies within the foreseeable future.

In Re The Welfare Of R.r.g., G.e.r., Ii v. Dshs · filed 2018-11-05(1)(d)

In these circumstances, additional housing assistance would have been futile and would not have remedied G.E.R.'s parental deficiencies within the foreseeable future.

Section 13.34.180(1)(d) requires necessary services to be expressly and understandably offered or provided to a parent.

Dependency Of H.k.f., B.d.: 9/1/15, Mariah Herd, App v. Dshs, Resp · filed 2018-11-13(1)(d)

Substantial evidence in the record supports the trial court's finding that mental health services were "expressly and understandably" offered or provided to Herd.

Section 13.34.180(1)(d) requires the Department to offer or provide necessary, reasonably available services capable of correcting parental deficiencies within the foreseeable future; it need not offer additional services that would be futile.

Dependency Of S.r.p.w. Dob: 3/14/12, Sharrah Wood v. Dshs · filed 2019-01-14(1)(d)

Substantial evidence supports the trial court’s determination that the Department offered or provided Wood with all reasonably availabie services capable of correcting her parentai deficiencies in the foreseeable future and that a neuropsychological evaiuation was not a necessary service.

Section 13.34.180(1)(d) does not require the Department to provide a service without evidence that it is reasonably necessary to correct parental deficiencies.

In re the Parental Rights to J.L.A.C.M. & H.A.M.M. · filed 2019-02-28(1)(d)

In the absence of any evidence that anger management was reasonably necessary for correcting Mr. McCarthy’s parental deficiencies, the Department had no obligation to provide the service.

A parent’s request alone does not make a service necessary under subsection (1)(d).

In Re The Dependency Of: D.r.n. Amber Kay Elliott, App. v. State Of Wa., Dshs, Res. · filed 2019-03-11(1)(d)

A parent's request for a service is not sufficient to convert that service to a necessary one.

The State need not offer housing services under subsection (1)(d) when they were not ordered and the parent did not establish that they were necessary at the termination trial.

In the Matter of the Parental Rights to: M.S.D., H.G.D., S.F.D. & N.L.M. · filed 2019-04-04(1)(d)

However, while the trial court identified inability to provide stable housing as a parental deficiency, it did not order J.D. to participate in housing services. Similarly, J.D. never contended at the termination trial that housing services were necessary and made no attempt to establish or argue that position to the trial court. Therefore, housing services were not necessary services under RCW 13.34.180(1)(d), and the State was not obligated to offer them.

The Department need not continue parenting education once the parents have completed it and parenting skills no longer prevent reunification.

In the Matter of the Parental Rights to: M.M.B. & R.J.B. · filed 2019-04-18(1)(d)

The Department had no obligation to continue to provide this service.

The Department satisfied subsection (1)(d) by offering necessary, reasonably available services capable of improving the parent’s deficiencies.

In Re The Dep Of C.r.s, C.barron. v. Dshs State Of Wa · filed 2019-04-29(1)(d)

In order to terminate parental rights, the Department must prove that it offered "all necessary services, reasonably available, capable of correcting the parental deficiencies within the foreseeable future." RCW 13.34.180(1)(d). ... These findings and credibility determinations support the ultimate finding that the Department offered necessary services, reasonably available, and capable of improving Christina's parental deficiencies.

The Department need not offer a court-ordered parenting evaluation when the parent has not met the order's visitation prerequisite.

In Re The Dependency Of L.a.n.: Cheryl Newell v. Dshs · filed 2019-06-10(1)(d)

Because Newell did not meet the prerequisite for this service, the Department was not obligated to offer it.

Section 13.34.180(1)(d) requires the State to offer necessary services but does not require it to explain the type of treatment likely to be provided within a court-ordered service.

In the Matter of the Parental Rights to: N.S.N. · filed 2019-06-27(1)(d)

She provides no legal authority for the proposition that the Department’s requirement to offer services operates at the granular level of explaining the type of treatment likely to be provided in the course of a court-ordered service.

Section 13.34.180(1)(d) allows a court to count necessary services a parent received from any source when deciding whether the Department met its duty to provide services.

In Re The Dependency Of N.p. Kate Daniels v. Dshs · filed 2019-07-08(1)(d)

When considering whether the Department provided all necessary services under RCW 13.34.180(1)(d), the court may consider any services that the parent receives, regardless of the source.