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6 canonical passages across 6 cases, quoted by 70 opinions in total. These passages cluster together because the same opinions keep quoting them side by side: they state parts of one doctrine. The anchor passage is from In Re Marr.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | In Re Marr Anchor | green | “a finding of unfitness does not necessarily require that the parent's rights be terminated.” | 27 |
| 2 | State, Department of Human Services v. Smith | green | “where . . . efforts to provide help to improve the parenting ability, offered over a long period of time, have proved ineffective, the conclusion that there is little likelihood of such improvement as would allow the safe return of the child to the parent in the near future is j…” | 16 |
| 3 | In re Navada N. | green | “the failure to remedy the conditions which led to the removal need not be willful.” | 13 |
| 4 | State, Department of Children's Services v. Estes | green | “its efforts do not need to be 'herculean.” | 8 |
| 5 | In Re Daymien T. | green | “a parent's continued inability to provide fundamental care to a child, even if not willful, . . . constitutes a condition which prevents the safe return of the child to the parent's care.” | 3 |
| 6 | In Re Addalyne S. | green | “this court has held that both the existence of a meaningful relationship and the lack of meaningful relationship may be considered important factors in the best interest analysis.” | 3 |
A red or yellow flag on a member means the underlying case has negative treatment: for those, check the case page before relying on the passage.