It is called Care and Protection of Walt.  It is a 2017 decision where DCF needs to make reasonable efforts to avoid removal of children and to reunify families after the children are removed.  The Juvenile Court needs to enforce these requirements through reasonable efforts and it has significant ability to order DCF to provide services where DCF has not made those reasonable efforts.  It also had described how the infrequent parent/child visits can harm this essential reunification and DCF should explore different short-term options as an alternative to taking custody of the child(ren).


It is a fairly strong case. It has mixed results in Juvenile Court regarding how it has worked at times and not worked, but it is something that is important to look at and to force DCF to show that they have made reasonable efforts.  Different Judges have had different opinions of it, but it is good case law at this time.