Wyo. Stat. » Wyo. Stat. / Title 14 - Children / Chapter 3 - PROTECTION / Article 4 - CHILD PROTECTION ACT

Wyo. Stat. § 14-3-440

Reasonable efforts for family reunification;

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exceptions.

     (a) Except as provided in W.S. 14-2-309(b) or (c),
reasonable efforts shall be made to preserve and reunify the
family:

          (i) Prior to placement of the child outside the home,
to prevent or eliminate the need for removing the child from the
child's home; and
          (ii) To make it possible for the child to safely
return to the child's home.

     (b) In determining what reasonable efforts shall be made
with respect to a child and in making those reasonable efforts,
the child's health and safety shall be the paramount concern.

     (c) Reasonable efforts to place a child for adoption or
with a legal guardian may be made concurrently with the
reasonable efforts described in subsection (a) of this section.

     (d) If continuation of reasonable efforts described in
subsection (a) of this section is determined to be inconsistent
with the permanency plan for the child, reasonable efforts shall
be made for placement of the child in a timely manner in
accordance with the permanency plan, and to complete the steps
necessary to finalize the permanent placement of the child.

     (e) Reasonable efforts determinations shall include
whether or not services to the family have been accessible,
available and appropriate.

     (f) The court shall make the reasonable efforts
determinations required under this section at every court
hearing. The reasonable efforts determinations shall be
documented in the court's orders.

     (g) If the court determines as provided in W.S.
14-2-309(a)(vi), (b) or (c) that reasonable efforts to preserve
and reunify the family are not required:

          (i) A permanency hearing as provided in W.S.
14-3-431(e) shall be held for the child within thirty (30) days
after the determination; and

          (ii) Reasonable efforts shall be made to place the
child in a timely manner in accordance with the permanency plan,
and to complete whatever steps are necessary to finalize the
permanent placement of the child.

     (h)   Repealed by Laws 2005, ch. 201, § 2.
Notes of Decisions
Cited in 26 cases (18 in the last 5 years), 2003–2026 · leading case: In the Interest of: BG, minor child, NG v. The State of Wyoming
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In the Interest of: BG, minor child, NG v. The State of Wyoming (2023) wyo · cites it 21× “Mother argues the definition of “family” under Wyo. Stat. Ann. § 14-3-440 (a) requires DFS to make reasonable efforts to reunify the minor child with more than just the minor child’s parents.”
Dunlap v. State (In re Bad) (2019) wyo · cites it 13× “See Wyo. Stat. Ann. § 14-3-440 (g), referencing Wyo.”
GS v. State (In re Interest of VS) (2018) wyo · cites it 8× “14-2-309(b) or (c), reasonable efforts shall be made to preserve and reunify the family: (i) Prior to placement of the child outside the home, to prevent or eliminate the need for removing the child from the child's home; and (ii) To make it possible for the child to safely…”
In the Interest of: SW, CW, HW and NW, minor children, KM v. The State of Wyoming (2021) wyo · cites it 8× “]” Wyo. Stat. Ann. § 14-3-440 (a); see Matter of BAD, 2019 WY 83 , ¶ 27, 446 P.”
In the Interest Of: RR, KR and RR, Minor Children, FR v. The State of Wyoming (2021) wyo · cites it 5× “” Wyo. Stat. Ann. § 14-3-440 (e). We have also observed, however, that there is a limit to what courts can require in the absence of parental cooperation.”
In the Interest of: AM, NM and IM, minor children, RR v. The State of Wyoming (2021) wyo · cites it 7× “While Wyo. Stat. Ann. § 14-3-440 requires DFS to make reasonable efforts to reunify children with 3 their family, “the statute also recognizes that .”
In the Interest of: JN, Minor Child, RN v. The State of Wyoming (2023) wyo · cites it 10× “” Wyo. Stat. Ann. § 14-3-440 (e). [¶13] Reasonable efforts by DFS and a determination by the juvenile court that DFS made these efforts are not mere formalities.”
In the Interest Of: BN and DN, Minor Children, NP v. The State of Wyoming (2022) wyo · cites it 12× “DISCUSSION [¶28] In neglect cases, Wyo. Stat. Ann. § 14-3-440 (a) requires DFS to “make reasonable efforts to ‘preserve and reunify the family[.”
In the Interest Of: Pt, Minor Child, Vt v. The State of Wyoming (2025) wyo · cites it 10× “]” Wyo. Stat. Ann. § 14-3-440 (a) (LexisNexis 2023).”
In the Interest Of: SK, MK, SK, SK and WM, minor children, MK v. The State of Wyoming (2024) wyo · cites it 4× “3d at 270 (quoting Wyo. Stat. Ann. § 14-3-440 (e)). “The Department’s efforts must also be tailored to the distinct circumstances of each case.”
In the Interest Of: Aa, a Minor Child, Ra v. The State of Wyoming (2021) wyo · cites it 2× “Section 14-3-440. Section 14-2- 309(c) states: (c) Notwithstanding any other provision of this section, evidence that reasonable efforts have been made to preserve and reunify the family is not required in any case in which the court determines any one (1) or more of the…”
In the Interest of JW v. State (2010) wyo · cites it 4× “] Also see Wyo. Stat. Ann. § 14-3-440 (LexisNexis 2009) (reasonable efforts shall be made to preserve and reunify the family); Wyo.”
Show all 26 citing cases →
— Wyo. Stat. § 14-3-440(a) — 2 cases
GS v. State (In re Interest of VS) (2018) wyo “14-2-309(b) or (c), reasonable efforts shall be made to preserve and reunify the family: (i) Prior to placement of the child outside the home, to prevent or eliminate the need for removing the child from the child's home; and (ii) To make it possible for the child to safely…”
In the Interest of: BG, minor child, NG v. The State of Wyoming (2023) wyo “Mother argues the definition of “family” under Wyo. Stat. Ann. § 14-3-440 (a) requires DFS to make reasonable efforts to reunify the minor child with more than just the minor child’s parents.”
— Wyo. Stat. § 14-3-440(b) — 1 case
GS v. State (In re Interest of VS) (2018) wyo “14-2-309(b) or (c), reasonable efforts shall be made to preserve and reunify the family: (i) Prior to placement of the child outside the home, to prevent or eliminate the need for removing the child from the child's home; and (ii) To make it possible for the child to safely…”
— Wyo. Stat. § 14-3-440(c) — 1 case
In the Interest Of: LC, Minor Child, TC v. The State of Wyoming (2025) wyo
— Wyo. Stat. § 14-3-440(d) — 2 cases
In Re Ndp (2009) wyo
CP v. State, Department of Family Services (2009) wyo
— Wyo. Stat. § 14-3-440(e) — 2 cases
In the Interest of: BG, minor child, NG v. The State of Wyoming (2023) wyo “Mother argues the definition of “family” under Wyo. Stat. Ann. § 14-3-440 (a) requires DFS to make reasonable efforts to reunify the minor child with more than just the minor child’s parents.”
In the Interest of: JN, Minor Child, RN v. The State of Wyoming (2023) wyo “” Wyo. Stat. Ann. § 14-3-440 (e). [¶13] Reasonable efforts by DFS and a determination by the juvenile court that DFS made these efforts are not mere formalities.”
— Wyo. Stat. § 14-3-440(f) — 2 cases
In the Interest Of: Pt, Minor Child, Vt v. The State of Wyoming (2025) wyo “]” Wyo. Stat. Ann. § 14-3-440 (a) (LexisNexis 2023).”
In the Interest of: JN, Minor Child, RN v. The State of Wyoming (2023) wyo “” Wyo. Stat. Ann. § 14-3-440 (e). [¶13] Reasonable efforts by DFS and a determination by the juvenile court that DFS made these efforts are not mere formalities.”
— Wyo. Stat. § 14-3-440(k) — 1 case
In the Interest Of: LC, Minor Child, TC v. The State of Wyoming (2025) wyo
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