South Carolina Department of Social Services v. M.R.C.L.

We granted certiorari to review the Court of Appeals’ decision in South Carolina Dept. of Social Services v. M.R.C.L., 390 S.C. 329, 701 S.E.2d 757 (Ct.App.2010). We reverse.

FACTS

The Department of Social Services (DSS) initiated termination of parental rights (TPR) proceedings against M.R.C.L. (mother) and R.L. (father). Child was removed from mother and father’s home in May 2007 due to allegations of physical neglect, after both parents tested positive for crack cocaine. Child, who was one year old at the time, was placed in a preadoptive foster home with two of her siblings. 1 Mother and…