In People in Interest of M.K., 466 N.W.2d 177, 178, 185 (S.D. 1991), social services removed a child from the custody of a mother, age 21, who was "borderline mentally retarded," because of concerns of her ability to care for the child. Id. at 178.

After social services worked with the mother for two years without significant improvement, it recommended terminating the mother's parental rights. Id. at 185.

The mother argued that, before terminating her parental rights, she "should have been afforded counseling through additional state programs; specifically, the Intensive Preventive Placement program (IPP) and Adult Foster Care." Id.

In rejecting the mother's argument, the Supreme Court of South Dakota explained that "there was no IPP counselor in her area," and "termination of parental rights is not conditioned upon exhaustion of every possible form of assistance." Id.