CS v. Department of Children and Families

In this dependency proceeding, the mother sought reunification with her child. After an evidentiary hearing, the trial court found substantial completion of her case plan but denied relief without making specific written, factual findings as to why-reunification would not be in the best interests of her child. She appeals. We reverse.

In E.I. v. Department of Children and Families, 979 So.2d 378 (Fla. 4th DCA 2008), we held that a court is obligated to comply with section 89.621(10), requiring the trial court to address and include in the written findings of fact the following six factors:(a)…