In In re Tiffany B., 228 S.W.3d 148 (Tenn. Ct. App. 2007), the appellate court interpreted Tennessee's enactment of the "reasonable efforts" requirement of ASFA.
The court stated, 228 S.W.2d at 158.
While the Department's efforts to assist parents need not be "herculean," the Department must do more than simply provide the parents with a list of service providers and then leave the parents to obtain services on their own. The Department's employees must bring their education and training to bear to assist the parents in a reasonable way to address the conditions that required removing their children from their custody and to complete the tasks imposed on them in the permanency plan.
The Tiffany B. court observed that the local department had made scant efforts to work with the parents. See id. at 159-60.
It concluded: "Despite its knowledge that the parents were addicted to crack cocaine, homeless, unemployed, and facing criminal charges, the Department apparently expected the parents to initiate the remedial efforts on their own and to ask their case manager for help. This expectation was unreasonable." Id. at 160.