In re William, Susan, & Joseph, 448 A.2d 1250 (R.I. 1982), involved the termination of parental rights of a mother who suffered from "moderate retardation." Id. at 1251, 1253.
The Supreme Court of Rhode Island held that the Department of Children and Their Families ("DCF") made "reasonable efforts" to foster the mother's parental relationship with her three children, even though it was not able to provide the mother with every service recommended by a psychologist hired by DCF. Id. at 1255-57.
The court noted that the term "'reasonable'" is "a word 'elastic in its nature . . . requiring consideration of the conditions and circumstances in determining what is reasonable in a particular situation.'" Id. at 1255.
The court found that, although DCF was unable to implement all of the psychologist's recommendations, it worked "conscientiously, and faithfully to encourage and strengthen the mother's parental relationship." Id. at 1256.
The court explained that, "just as the mother's particular needs are factored into the 'reasonable efforts' equation, so too must be the reality that many of the services DCF might ideally have provided were unacceptable to Gloria or unavailable through the department." Id.
Thus, the failure to render all services recommended did not prevent a finding that the Department's efforts were reasonable. Id. at 1256-57.