Editor's notes.

- In light of the similarity of the statutory provisions, decisions under former Code 1933, § 24A-2701, pre-2000 Code Section 15-11-41, and pre-2014 Code Section 15-11-58, which were subsequently repealed but were succeeded by provisions in this Code section, are included in the annotations for this Code section. See the Editor's notes at the beginning of the chapter.

Applicability.

- Former O.C.G.A. § 15-11-58(a) (see now O.C.G.A. §§ 15-11-2 and15-11-134) was inapplicable since a child remained in the legal custody of the child's father with whom the child had been residing for several months prior to the deprivation hearing as the child was not placed in the custody of the Georgia Department of Family and Children Services. In the Interest of K.J., 268 Ga. App. 843, 602 S.E.2d 861 (2004) (decided under former O.C.G.A. § 15-11-58).

In a termination of parental rights case, the court rejected the parents' argument that the parents had been deprived of the opportunity to achieve reunification under former O.C.G.A. § 15-11-58(a)(2) (see now O.C.G.A. § 15-11-202) because the Department of Family and Children Services had not promptly presented a second reunification plan; while the parents had made laudable efforts to comply with the second case plan, the parent had not complied with the first plan; moreover, former § 15-11-58 did not apply to termination proceedings. In the Interest of T.W.O., 283 Ga. App. 771, 643 S.E.2d 255 (2007) (decided under former O.C.G.A. § 15-11-58).

Notice.

- At a permanency hearing, at which a mother appeared represented by counsel, the mother was not entitled to prior notice by report or motion that DFCS would seek termination of reunification services and an award of long-term custody at the hearing. In the Interest of D. H., 313 Ga. App. 664, 722 S.E.2d 388 (2012) (decided under former O.C.G.A. § 15-11-58).

Presumption that reunification services are inappropriate.

- Pursuant to former O.C.G.A. § 15-11-58(h) (see now O.C.G.A. § 15-11-204), reunification services were inappropriate if reasonable efforts to reunify a child with the child's family would be detrimental to the child; although rebuttable, a presumption existed. In the Interest of J.P.V., 261 Ga. App. 194, 582 S.E.2d 170 (2003) (decided under former O.C.G.A. § 15-11-58).

Juvenile court's decision to terminate parental rights was supported by clear and convincing evidence including the family's history of instability, the fact that the children lived in filth for their entire lives, their developmental and emotional problems, and evidence of malnourishment and poor hygiene. The mother failed to rebut the presumption that reunification services should not be provided to the family and that efforts to reunify the children with the mother would be detrimental to the children. In the Interest of T.D.B., 266 Ga. App. 434, 597 S.E.2d 537 (2004) (decided under former O.C.G.A. § 15-11-58).

Because the parental rights to a mother's other four children had previously been terminated around the time the mother's infant child was born, the juvenile court did not err in approving a nonreunification plan involving that infant child pursuant to former O.C.G.A. § 15-11-58(a)(4)(C) (see now O.C.G.A. § 15-11-203); further, a presumption of nonreunification arose based on the mother's medically verified mental deficiency. In the Interest of J.P., 280 Ga. App. 100, 633 S.E.2d 442 (2006) (decided under former O.C.G.A. § 15-11-58).

Presumption against reunification.

- Because there was no evidence that parents suffered from a medically verifiable deficiency of their mental health, no presumption against reunification arose on such account. In the Interest of A.M., 306 Ga. App. 358, 702 S.E.2d 686 (2010) (decided under former O.C.G.A. § 15-11-58).

Notice of nonreunification.

- Parent had notice that the Georgia Department of Family and Children Services was seeking nonreunification and had the opportunity to contest the issue; after a hearing the court continued the case, noting that a nonreunification case plan had been filed and the parent was contesting the issue of nonreunification, and the hearing was held on the later date with the parent and the parent's attorney present at the hearing. In the Interest of A. E., 314 Ga. App. 206, 723 S.E.2d 499 (2012) (decided under former O.C.G.A. § 15-11-58).

Reasonable efforts at reunification not required.

- Reasonable efforts toward reunification of a father with his child were not required because the court made findings of aggravated circumstances including a finding that the father had sexually abused the child and the child's siblings. In the Interest of B.M., 252 Ga. App. 716, 556 S.E.2d 883 (2001) (decided under former O.C.G.A. § 15-11-58).

Clear and convincing evidence supported a juvenile court's judgment that reunification services were inappropriate for a mother with a history of drug and alcohol use, whose minor child had been taken from her home on three occasions because of the mother's inability to provide adequate food, clothing, and shelter for the child. In the Interest of J.P.V., 261 Ga. App. 194, 582 S.E.2d 170 (2003) (decided under former O.C.G.A. § 15-11-58).

Although former O.C.G.A. § 15-11-58(a) (see now O.C.G.A. §§ 15-11-2 and15-11-134) required a juvenile court to make a finding of fact as to whether reasonable efforts at reunification were made prior to placement of the children in a county agency in a parental rights termination proceeding, such finding was not required because the children had already been found to be deprived by the mother. In the Interest of S.N.L., 275 Ga. App. 600, 621 S.E.2d 792 (2005) (decided under former O.C.G.A. § 15-11-58).

Termination of a parent's rights to a child was not barred by the parent's claim that a county department of family and children services established a nonreunification plan before contacting the parent and then denied the parent's requests for information; former O.C.G.A. § 15-11-58 did not impose upon termination proceedings the same procedures that applied to disposition orders and recommendations regarding reunification and did not obligate the department in every case to create a plan for reunification, and when the department afforded the parent an opportunity to participate in the case by mailing the initial case plan to the parent and explaining the need to legitimize the child, the parent failed to seize the opportunity or to comply timely with the instructions on legitimization. In the Interest of T.C., 282 Ga. App. 659, 639 S.E.2d 601 (2006) (decided under former O.C.G.A. § 15-11-58).

Reasonable efforts at reunification.

- Because a caseworker began working with the father even before he established paternity, and because the Department of Family and Children Services prepared a case plan for the father, pursuant to former O.C.G.A. § 15-11-58(a)(1) (see now O.C.G.A. § 15-11-202), reasonable efforts were made to place the child with the father before the child was placed with the Department. In re T.B.W., 312 Ga. App. 733, 719 S.E.2d 589 (2011) (decided under former O.C.G.A. § 15-11-58).

Reunification plan.

- Because the juvenile court entered court-ordered goals for reunification, but failed to enter a specific plan for reunification after the deprivation finding, and the mother's attorney was left with virtually no time to file any motions requesting visitation or a case plan for reunification, under the mandate of former O.C.G.A. § 15-11-58(a)(2) (see now O.C.G.A. § 15-11-202), the juvenile court was required to set out a plan for reunification and give the mother the opportunity to meet those goals. In the Interest of B.C., 250 Ga. App. 152, 550 S.E.2d 707 (2001) (decided under former O.C.G.A. § 15-11-58).

Mother's claim that the reunification plan that the state family welfare department imposed on her was too vague to comply with the applicable statutory requirements was waived because that claim was not raised in the trial court, but, in any event, the plan was sufficiently specific to meet the statutory requirements. In the Interest of D.E., 269 Ga. App. 753, 605 S.E.2d 394 (2004) (decided under former O.C.G.A. § 15-11-41).

Failure to comply with previous reunification plan.

- One of the noted factors in finding a child to be deprived was proof that a parent had unjustifiably failed to comply with a previously ordered plan designed to reunite the family under former O.C.G.A. § 15-11-58(h)(1) (see now O.C.G.A. § 15-11-204). In the Interest of R.M., 276 Ga. App. 707, 624 S.E.2d 182 (2005).

Reunification not appropriate.

- Evidence that reunification would subject the child to further educational neglect, inadequate supervision, and domestic violence, that the mother's cognitive limitations placed the child at risk, that the mother failed to make progress despite intervention, and that there were no other services that could be provided to eliminate the risk of harm to child, made it clear reunification would be detrimental. In re C.N., 231 Ga. App. 639, 500 S.E.2d 400 (1998) (decided under former O.C.G.A. § 15-11-41).

Since the evidence showed that children were deprived due to a mother's lack of parental care, that the deprivation was likely to continue and cause serious harm to the children, and that the mother unjustifiably failed to comply with previous reunification plans, the trial court did not err in approving the nonreunification plan. In re C.S., 236 Ga. App. 312, 511 S.E.2d 895 (1999) (decided under former O.C.G.A. § 15-11-41).

Reunification was not appropriate since evidence showed that parents unjustifiably failed to comply with plans designed to reunite the parents with the children, the children were removed from the parents' custody on two or more occasions, reunification services were previously provided, and there were grounds for terminating parental rights. In re R.U., 239 Ga. App. 573, 521 S.E.2d 610 (1999) (decided under former O.C.G.A. § 15-11-41).

Juvenile court did not err in approving a nonreunification plan when convincing evidence showed reunification was not in the best interests of the children and the likelihood that it would only prolong their deprivation. In the Interest of U.B., 246 Ga. App. 328, 540 S.E.2d 278 (2000) (decided under former O.C.G.A. § 15-11-41).

Evidence that the children's mother permitted and/or assisted her husband in making videotapes for distribution of the children being stripped and spanked was sufficient to show that reunification services between the children and their mother should not be provided under former O.C.G.A. § 15-11-58(h) (see now O.C.G.A. § 15-11-204); furthermore, a presumption against nonreunification existed because of the evidence of the mother's past egregious conduct, and there was insufficient evidence to overcome the presumption favoring reunifications. In the Interest of J.P., 253 Ga. App. 732, 560 S.E.2d 318 (2002) (decided under former O.C.G.A. § 15-11-41).

Reunification was not appropriate since evidence of the children's starvation, coupled with the mother's complete denial of responsibility for their emaciated condition, amply supported the juvenile court's findings that she physically neglected the children and that reunification would be detrimental to the children. In the Interest of R.N.R., 257 Ga. App. 93, 570 S.E.2d 388 (2002) (decided under former O.C.G.A. § 15-11-41).

Evidence was sufficient to support a juvenile court's approval of nonreunification of the mother and her child under former O.C.G.A. § 15-11-58(h) (see now O.C.G.A. § 15-11-204) as the mother failed to rebut the presumption that reunification services not be provided due to her medically verifiable health deficiency when the mother provided evidence that she complied with her prenatal care, did fine during pregnancy even though she was not on her medication, and was a loving mother, but a psychiatrist testified that the mother was mentally ill, that the illness could cause the mother to hurt the child, and that the mother's mental condition was likely to continue. In the Interest of D.L.W., 264 Ga. App. 168, 590 S.E.2d 183 (2003).

As the trial court found clear and convincing evidence of a medically verifiable condition creating the parent's inability to properly parent the children, this finding created a presumption that reunification services need not be provided. In the Interest of A.W., 264 Ga. App. 705, 592 S.E.2d 177 (2003) (decided under former O.C.G.A. § 15-11-58).

Evidence was sufficient to support the trial court's judgment that reunification efforts should be discontinued as to the mother as clear and convincing evidence showed that the mother had not, as required by the reunification plan, gone six consecutive months without testing positive for drugs and had refused to submit to two drug screenings; also, the mother had not rebutted the presumption that reunification efforts should be discontinued. In the Interest of J.B., 274 Ga. App. 564, 618 S.E.2d 187 (2005) (decided under former O.C.G.A. § 15-11-58).

Plan for nonreunification under former O.C.G.A. § 15-11-58(h) (see now O.C.G.A. § 15-11-204) was in the child's best interests since: (1) the grandmother relapsed after regaining custody and became so drunk that she passed out and left the four-year-old child unsupervised; (2) the incident resulted in the grandmother's father applying for a protection order; (3) the grandmother was dismissed from a substance abuse treatment program; (4) the grandmother pled guilty to driving under the influence and child endangerment two years earlier; and (5) the child had behavioral problems that resulted in hospitalization and that led a child services agency to seek therapeutic foster care before seeking permanent adoption. In the Interest of J.B., 274 Ga. App. 20, 619 S.E.2d 305 (2005) (decided under former O.C.G.A. § 15-11-58).

Trial court properly granted an agency's motion to end reunification services provided to the parents as the evidence indicated that the parents refused to cooperate with case plans and had completely denied responsibility for placing the children in a harmful situation. In the Interest of D.B., 277 Ga. App. 454, 627 S.E.2d 101 (2006) (decided under former O.C.G.A. § 15-11-58).

Rational trier of fact could have found clear and convincing evidence that the parent unjustifiably failed to comply with the reunification plan and that reasonable efforts to reunify the child with the parent would be detrimental to the child under former O.C.G.A. § 15-11-58(h) (see now O.C.G.A. § 15-11-204); the parent failed to complete parenting classes, failed to obtain stable housing and employment, failed to pay child support, failed to attend psychotherapy, and disappeared for months at a time without explanation and without visiting the child. In the Interest of C.A., 279 Ga. App. 747, 632 S.E.2d 698 (2006) (decided under former O.C.G.A. § 15-11-58).

In the termination of parental rights case, contrary to the mother's argument, the reunification plan complied with former O.C.G.A. § 15-11-58(c)(3) (see now O.C.G.A. § 15-11-201); the plan required the mother, who was mentally retarded, to prove that the mother could be a fit parent, and the mother failed to show this. In the Interest of H.F.G., 281 Ga. App. 22, 635 S.E.2d 338 (2006) (decided under former O.C.G.A. § 15-11-58).

Order holding that reunification efforts on the part of a mother were not in the best interest of her two children was upheld on appeal pursuant to former O.C.G.A. § 15-11-58(h) (see now O.C.G.A. § 15-11-204) since the record established that the mother suffered from mental illness and was unable to care for her children. The mother failed to rebut the presumption that reunification services were inappropriate when she had unjustifiably failed to comply with a previously ordered plan. In the Interest of T.L., 285 Ga. App. 526, 646 S.E.2d 728 (2007) (decided under former O.C.G.A. § 15-11-58).

Although a parent made substantial progress on a reunification plan while incarcerated, an order extending temporary custody for an additional year in favor of the Department of Family and Children Services was upheld on appeal as sufficient evidence was presented that the parent was unable to: (1) establish stable housing; (2) complete a substance abuse assessment; and (3) demonstrate six months of clean drug screens; further, as the parent was living with the other parent who evidence showed to be an unrehabilitated drug user, the trial court was authorized to conclude that the child at issue would not be in a safe environment if returned to the parent. In the Interest of R.B., 285 Ga. App. 556, 647 S.E.2d 300 (2007) (decided under former O.C.G.A. § 15-11-58).

Juvenile court did not err in approving nonreunification with regard to a parent and two twin children as some evidence showed that the parent: unjustifiably failed to comply with the case plan goals to provide financial support for the children; failed to maintain stable housing and employment; failed to attend all scheduled psychological evaluations; exhibited paranoid and psychopathic personality tendencies to the extent that the parent's ability to care for the children was severely impaired; and was convicted of threatening a prior spouse and stalking that spouse and children and, thus, had engaged in actions which constituted egregious conduct toward those children. In the Interest of T.W., 288 Ga. App. 386, 654 S.E.2d 218 (2007) (decided under former O.C.G.A. § 15-11-58).

Trial court properly extended a department of family and child services' custody of a child when the child's mother, communicating with the child over the Internet while posing as an adult man, had pretended to have witnessed a sexually graphic event; the child was especially vulnerable to sexually inappropriate behavior; and the mother's conduct during visitation with the child, including her statements that the child would be a suspect if anything happened to the mother, that the child would never live with her father, and that the child was "acting like a whore," was also probative of whether she would act abusively toward her daughter if she were returned to her custody. The fact that the mother had substantially completed her reunification case plan did not mandate that the child be returned to her custody. In the Interest of Q.H., 291 Ga. App. 598, 662 S.E.2d 358 (2008) (decided under former O.C.G.A. § 15-11-58).

There was sufficient clear and convincing evidence presented to authorize the juvenile court to find that a mother's child was deprived and that the deprivation was likely to continue, and consequently, that reunification of the child with the mother would be detrimental to the child and was not in the child's best interest because, while the juvenile court took into consideration the previous termination of the mother's parental rights in determining whether the child was deprived, the juvenile court also heard substantial evidence showing that the mother's mental, emotional, and financial condition had not changed significantly since her parental rights to her children were terminated and that, despite the assistance of the Department of Family and Children Services and the loss of her four children, the mother still lacked the necessary skills, judgment, and resources to properly care for the child. In re R. B., 309 Ga. App. 407, 710 S.E.2d 611 (2011) (decided under former O.C.G.A. § 15-11-58).

Juvenile court did not err in terminating the reunification services and approving the non-reunification plan because clear and convincing evidence supported the juvenile court's conclusion that the child was deprived based on the mother's long-term substance abuse and that such deprivation was likely to continue and cause harm to the child. In the Interest of J. T., 322 Ga. App. 4, 743 S.E.2d 571 (2013) (decided under former O.C.G.A. § 15-11-58).

Reunification inappropriate when children had severe medical issues.

- Trial court did not err in granting a motion filed by the Department of Family and Children Services for nonreunification because evidence supported the trial court's finding that the parents were not able to meet their children's medical needs, and the children's lives would be endangered if the appropriate level of care was not maintained; the parents' physical neglect of the children and their continuing inability to meet their children's extensive medical needs was sufficient for any rational trier of fact to find by clear and convincing evidence that reunification efforts would be detrimental to the children. In the Interest of A.M., 306 Ga. App. 358, 702 S.E.2d 686 (2010) (decided under former O.C.G.A. § 15-11-58).

Report recommending nonreunification met requirements of former O.C.G.A. § 15-11-58(b) (see now O.C.G.A. § 15-11-200), notwithstanding evidence which the mother contended showed that the contents of the report recommending nonreunification were determined prior to her meeting with caseworkers for the county Department of Family and Children Services. Although the court agreed with the mother that a report should not be finalized until after such a meeting had been conducted, it disagreed with the mother's apparent contention that nothing should be committed to writing prior to such meeting. In the Interest of T.R., 248 Ga. App. 310, 548 S.E.2d 621 (2001) (decided under former O.C.G.A. § 15-11-58).

Discontinuing efforts for reunification appropriate.

- Because a trial court found in the court's unappealed orders that the children were deprived and that such deprivation was caused by their father, in a second unappealed order finding that the deprivation was likely to continue and that the father was untruthful, evasive, and inconsistent in his testimony, the statutory criteria for discontinuing efforts for reunification of the family were met. In re L.S.M., 236 Ga. App. 537, 512 S.E.2d 397 (1999) (decided under former O.C.G.A. § 15-11-41).

Denial of reunification was proper based on findings that this was the third time that the children had been removed from the mother's care, that the Department of Family and Children Services had previously undertaken reasonable efforts to reunify the family, that the mother had unjustifiably failed to comply with prior plans, and that she had serious medical problems. In re K.M., 240 Ga. App. 67, 522 S.E.2d 667 (1999) (decided under former O.C.G.A. § 15-11-41).

Order terminating reunification services was proper after a case manager testified that the mother did not meet the case plan requirements, and although the mother claimed that she worked "daily" to clean up her house and satisfy the other case plan goals, she readily admitted that she failed to make her home safe for the child within the 90-day time period established by the court. In the Interest of B.D.G., 262 Ga. App. 843, 586 S.E.2d 736 (2003) (decided under former O.C.G.A. § 15-11-58).

Termination of reunification services was affirmed since the evidence showed that the parent had a history of chronic unrehabilitated abuse of alcohol or controlled substances with the effect of rendering the parent incapable of providing adequately for the needs of the children. In the Interest of S.A., 263 Ga. App. 610, 588 S.E.2d 805 (2003) (decided under former O.C.G.A. § 15-11-58).

Record supported the juvenile court's judgment that a parent did not fulfill the terms of a case plan that was established by the Department of Family and Children's Services because the parent continued using cocaine and refused to attend substance abuse treatment; thus, the child was deprived and custody was properly placed in the department. In the Interest of J.L., 269 Ga. App. 226, 603 S.E.2d 742 (2004) (decided under former O.C.G.A. § 15-11-58).

Because a mother unjustifiably failed to comply with the court-ordered case-plan goals, ample evidence supported the juvenile court's order approving the termination of reunification services under former O.C.G.A. § 15-11-58(h) (see now O.C.G.A. § 15-11-204). In the Interest of K.R., 270 Ga. App. 296, 605 S.E.2d 911 (2004) (decided under former O.C.G.A. § 15-11-58).

Because a presumption of non-unification arose after a parent failed to pay child support or comply with the reunification plan, reunification services were properly discontinued; but a placement order with a foster care agency was reversed as a grandparent presented uncontradicted evidence supporting a consideration for alternative placement. In the Interest of J.J., 287 Ga. App. 746, 652 S.E.2d 639 (2007) (decided under former O.C.G.A. § 15-11-58).

Juvenile court properly terminated reunification services under since the child's parent had been incarcerated for the majority of the child's life and faced additional jail time if convicted of several pending charges, and the parent's child enjoyed a significant bond with the child's aunt and uncle, with whom the child had lived for several years. In the Interest of C.P., 291 Ga. App. 699, 662 S.E.2d 802 (2008) (decided under former O.C.G.A. § 15-11-58).

Grant of a petition to cease efforts to reunify the mother with the mother's three children was supported by evidence that the mother continued to live with the mother's drug-supplier boyfriend and use illegal drugs, had not obtained a source of income, and had not ensured that the children had no contact with the mother's boyfriend, who allegedly touched one of the children inappropriately. In the Interest of R. G., 322 Ga. App. 523, 745 S.E.2d 752 (2013).

Discontinuing efforts for reunification not appropriate.

- Evidence that the mother had substantially complied with the reunification plan and that, in the opinion of the psychologist retained by the Department of Family and Children Services, the psychologist did not understand why the department was seeking to end reunification efforts when the only way it was possible to determine if the mother would be able to effectively parent her eight year old child in the future was by reuniting the mother and child overcame the statutory presumption that reunification was not appropriate in cases when a child had been removed from the mother's home on at least two prior occasions and reunification services had been made available on those occasions. In the Interest of M.H., 251 Ga. App. 528, 554 S.E.2d 616 (2001) (decided under former O.C.G.A. § 15-11-58).

Because the record failed to contain clear and convincing evidence to support the termination of reunification services to a parent, but instead showed that the parent substantially met the goals outlined in the reunification plan, maintained an income level appropriate to meet the needs of the parent's family, and cooperated in submitting to a psychological evaluation and any recommended treatment, that part of the lower court's judgment was reversed; but, the denial of the parent's reunification motion and the extension of temporary custody was affirmed. In the Interest of S.L.E., 280 Ga. App. 145, 633 S.E.2d 454 (2006) (decided under former O.C.G.A. § 15-11-58).

Trial court improperly granted a motion filed by the Department of Family and Children Services to discontinue efforts to reunify parents with their children because the trial court erred in finding that the parents suffered from a medically verifiable deficiency of their mental health such as to render them incapable of providing for the physical needs of the children; the four psychological reports, two for each parent, that were submitted into evidence for consideration by the trial court provided no evidentiary support for the trial court's finding of a "medically verifiable deficiency" of the parents' mental health because the reports did not suggest that either parent lacked the mental competency to care for their children. In the Interest of A.M., 306 Ga. App. 358, 702 S.E.2d 686 (2010) (decided under former O.C.G.A. § 15-11-58).

A juvenile court's orders terminating reunification services and awarding custody of a child to the maternal grandmother were not supported by clear and convincing evidence because the mother demonstrated that she had Supplemental Security Income for two other children and that she could live comfortably with her children at her mother's home. In the Interest of D. H., 313 Ga. App. 664, 722 S.E.2d 388 (2012) (decided under former O.C.G.A. § 15-11-58).

Failure to challenge deprivation order.

- Failure to challenge a deprivation order precluded a parent's challenge to the sufficiency of the evidence showing that reasonable reunification efforts were made. In the Interest of R.D.B., 282 Ga. App. 628, 639 S.E.2d 565 (2006) (decided under former O.C.G.A. § 15-11-58).

Finding of reunification efforts not required.

- Because the children had not been placed in the custody of the Department of Family and Children Services, the trial court was not required to find that the agency had made reasonable reunification efforts. In the Interest of T.R., 284 Ga. App. 742, 644 S.E.2d 880 (2007) (decided under former O.C.G.A. § 15-11-58).

Failure to make reasonable efforts.

- Even assuming that the Department of Family and Children Services made no reasonable effort to prevent a newborn's removal from her mother's custody, the juvenile court's factual findings that the mother's older child had been removed months earlier due to physical abuse inflicted by the mother, her boyfriend, or both, and that the newborn was the child of the mother and her boyfriend, who had since married, supported the award of custody to the Department pursuant to O.C.G.A. § 15-11-202(g). In the Interest of S. C. S., 336 Ga. App. 236, 784 S.E.2d 83 (2016).

Parent's complicity in murder did not excuse lack of reunification efforts.

- When a mother's boyfriend was charged with murdering one of her three children, and she was charged with complicity, and since there was no evidence she knew that the boyfriend abused her children, and none of the aggravated circumstances contained in former O.C.G.A. § 15-11-58(a)(4)(A)-(C) (see now O.C.G.A. § 15-11-203) had been shown, the trial court erred in excusing the state from making reasonable efforts toward reunification. In the Interest of A.B., 263 Ga. App. 697, 589 S.E.2d 264 (2003) (decided under former O.C.G.A. § 15-11-58).

Reunification plan requiring English classes.

- Trial court did not misread parents' case plan to include goals that were not expressed in the plan because evidence supported the trial court's finding that the parents' case plan required the parents to have a psychological examination and follow through with recommended treatment; because the psychologist who recommended English as a second language classes pointed to the parents' language limitations as causing them to miss information necessary to provide appropriate medical care for the children, the recommended action was directly related to the circumstances which required the children be separated from the parents, and the recommended action could be included in the case plan without further judicial review. In the Interest of A.M., 306 Ga. App. 358, 702 S.E.2d 686 (2010) (decided under former O.C.G.A. § 15-11-58).

Reunification order insufficient to allow for meaningful appellate review.

- Juvenile court's order that reunification was not in a child's best interests was vacated because the juvenile court found that reunification efforts would be detrimental to the child but did not specify which, if any, of the presumptions under former O.C.G.A. § 15-11-58(h) (see now O.C.G.A. § 15-11-204) supported the court's finding; therefore, it was impossible for the court of appeals to determine whether the order was supported by clear and convincing evidence. In re T.S., 310 Ga. App. 100, 712 S.E.2d 121 (2011) (decided under former O.C.G.A. § 15-11-58).