T.R. v. Indiana DCS — Father’s Termination Reversed Where DCS Never Deployed Its Own Housing-Assistance Tools
The Indiana Court of Appeals affirmed the termination of a mother’s parental rights but reversed the termination of a father’s rights as to his two biological children. The father complied fully with every ordered service, held a job, and maintained consistent visitation; his only obstacle was stable housing blocked by his criminal history. Because DCS never sought a waiver for a sister-in-law’s disqualified home despite a written policy allowing it, and never followed through on deposit assistance when the father found an apartment one week before the termination hearing, the court held that DCS failed to make reasonable efforts and that proceeding to terminate his rights violated due process.