DYFS v. M.D.C. and R.C./In the Matter of B.M.C., unpublished opinion, App. Div. Docket No. A-5579 and 5655-07T4 (December 9, 2009) – Order terminating parental rights reversed, case remanded. The trial court’s decision contained insufficient and inaccurate factual findings with respect to the four prongs of N.J.S.A. 30:4C-15.1(a).
In particular, NJ DYFS failed to obtain a bonding assessment with the child’s foster parents before concluding that termination would not do more harm than good. The absence of any evidence that DYFS made any effort to investigate and assist defendants in addressing whatever problems caused them to lose their housing negated the finding that it made reasonable efforts to provide services to defendants. (Michael C. Wrobleski, Designated Counsel, for M.D.C.; Durrell Wachtler Ciccia, Designated Counsel, for R.C.; Jeffrey R. Jablonski, A.D.P.D., Law Guardian)