rigid standard in Rhode Island

2023We have stated in that regard that “the concept of reasonable efforts is not a rigid standard, but one of some flexibility * * *.” In re Amber P., 877 A.2d 608, 618 (R.I. 2005); see also In re Jah-nell B., 9 At oral argument before this Court, Esmeralda’s attorney conceded that DCYF had made reasonable efforts prior to her commitment to Eleanor Slater Hospital. - 15 - 116 A.3d at 793 .

2015Instead, this Court has previously'stated that “the concept of reasonable efforts is not a rigid standard, but one of some flexibility that must be defined by the particular facts and circumstances in a case.” In re Alvia K., 909 A.2d at 504 (quoting In re Amber P., 877 A.2d at 618 ).

2011We note that “the concept of reasonable efforts is not a rigid standard, but one of some flexibility that must ‘be defined by the particular facts and circumstances in a case.’” In re Alvia K., 909 A.2d 498, 504 (R.I.2006) (quoting In re Amber P., 877 A.2d 608, 618 (R.I.2005)); see also In re Alan W., 665 A.2d 877, 878 (R.I.1995) (explaining that, although “[rjeasonable efforts” are determined on a case-by-case basis, the efforts “must include case planning with the parent, arrangements for visitation, and keeping the parent informed of the child’s well-being”).

2006In re Amber P., 877 A.2d at 618 ; see also § 15-7-7(b)(1). “[T]he concept of reasonable efforts is not a rigid standard, but one of some flexibility that must ‘be defined by the particular facts and circumstances in a case.’ ” In re Amber P., 877 A.2d at 618 (quoting In re Alan W., 665 A.2d 877, 878 (R.I.1995)).

2015Instead, this Court has previously'stated that “the concept of reasonable efforts is not a rigid standard, but one of some flexibility that must be defined by the particular facts and circumstances in a case.” In re Alvia K., 909 A.2d at 504 (quoting In re Amber P., 877 A.2d at 618 ).

2011We note that “the concept of reasonable efforts is not a rigid standard, but one of some flexibility that must ‘be defined by the particular facts and circumstances in a case.’” In re Alvia K., 909 A.2d 498, 504 (R.I.2006) (quoting In re Amber P., 877 A.2d 608, 618 (R.I.2005)); see also In re Alan W., 665 A.2d 877, 878 (R.I.1995) (explaining that, although “[rjeasonable efforts” are determined on a case-by-case basis, the efforts “must include case planning with the parent, arrangements for visitation, and keeping the parent informed of the child’s well-being”).

2023Significantly, DCYF is not required to “demonstrate that it took extraordinary efforts;” but rather it must “employ reasonable efforts, and the reasonableness of such efforts must be determined from the particular facts and circumstances of each case.” In re Violet G., 212 A.3d 160, 167 (R.I. 2019) (internal quotation marks omitted); see also Jae’La G., 276 A.3d 378 , 391 (R.I. 2022); In re Rosalie H., 889 A.2d 199, 208 (R.I. 2006).

2023Significantly, DCYF is not required to “demonstrate that it took extraordinary efforts;” but rather it must “employ reasonable efforts, and the reasonableness of such efforts must be determined from the particular facts and circumstances of each case.” In re Violet G., 212 A.3d 160, 167 (R.I. 2019) (internal quotation marks omitted); see also Jae’La G., 276 A.3d 378 , 391 (R.I. 2022); In re Rosalie H., 889 A.2d 199, 208 (R.I. 2006).

2023We have stated in that regard that “the concept of reasonable efforts is not a rigid standard, but one of some flexibility * * *.” In re Amber P., 877 A.2d 608, 618 (R.I. 2005); see also In re Jah-nell B., 9 At oral argument before this Court, Esmeralda’s attorney conceded that DCYF had made reasonable efforts prior to her commitment to Eleanor Slater Hospital. - 15 - 116 A.3d at 793 .

2006See Rafferty v. Cranston Public School Committee, 315 F.3d 21, 26 (1st Cir.2002); Frazier, 276 F.3d at 64 ; Rose, 214 F.3d at 210 ; Weber v. Cranston School Committee, 212 F.3d 41, 51-52 (1st Cir.2000).

2006See Rafferty v. Cranston Public School Committee, 315 F.3d 21, 26 (1st Cir.2002); Frazier, 276 F.3d at 64 ; Rose, 214 F.3d at 210 ; Weber v. Cranston School Committee, 212 F.3d 41, 51-52 (1st Cir.2000).

2005However, we have recognized that the concept of reasonable efforts is not a rigid standard, but one of some flexibility that must “be defined by the particular facts and circumstances in a case[.]” Id. (citing In re Ann Marie, 461 A.2d 394, 395 (R.I.1983)).

2000Collateral estoppel is a more rigid doctrine, in that it “bars litigation of an issue when that issue has been determined by a valid and final judgment.” DeCiantis v. State, 666 A.2d 410, 412 (R.I.1995).

2000Collateral estoppel is a more rigid doctrine, in that it "bars litigation of an issue when that issue has been determined by a valid and final judgment." DeCiantis v. State, 666 A.2d 410, 412 (R.I.1995).

2000The doctrine of res adjudicata has an even greater preclusive effect, in that “it makes a prior judgment in a civil action between the same parties conclusive with regard to any issues that were litigated in the prior action, or, that could have been presented and litigated therein.” ElGabri v. Lekas, 681 A.2d 271, 275 (R.I.1996).

2000The doctrine of res adjudicata has an even greater preclusive effect, in that "it makes a prior judgment in a civil action between the same parties conclusive with regard to any issues that were litigated in the prior action, or, that could have been presented and litigated therein." ElGabri v. Lekas, 681 A.2d 271, 275 (R.I.1996).