Department of Social & Health Services v. H.O.

¶1 Petitioner H.O. asks us to reverse the Court of Appeals’ decision affirming the termination of her parental rights. She argues that the State failed to prove two prerequisites to termination, one statutory and one constitutional. The statutory prerequisite is codified at RCW 13.34.180(1)(d); it requires the State to prove that it has offered and provided “all necessary services, reasonably available, capable of correcting the parental deficiencies within the foreseeable future.” The constitutional prerequisite is a finding (express or implied) of parental unfitness. We agree with H.O. that…