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“The nature of the services which constitute ‘reasonable efforts’ depends on the problem presented.”

“The district court must also determine that, at the time of termination, the parent is not presently able and willing to as sume [those] responsibilities and that the condition will continue for the reasonably foreseeable future.” (instructing the district court to “address conditions that exist at the time of the hearing”).

14 Whether the county provided reasonable efforts requires a context-specific analysis that “depends on the problem presented.”

Whether the county provided reasonable efforts requires a context-specific analysis that “depends on the problem presented.”

Whether the agency provided reasonable efforts depends “on the problem presented.”

(stating that a district court’s TPR decision relies “not primarily on past history, but to a great extent upon the projected permanency of the parent’s inability to care for his or her child” (quotation omitted)).

-94 (Minn. 1996) (concluding that, although father was doing well at time of trial, district court properly considered his long history of mental illness and substance abuse when terminating his parental rights).

-94 (Minn. 1996) (providing that, although father was doing well at the time of trial, the district court properly considered his long history of mental illness and substance abuse when terminating his parental rights); see also In re Welfare of Child.

“The district court must also determine that, at the time of termination, the parent is not presently able and willing to assume her responsibilities and that the condition will continue for the reasonably foreseeable future.” (instructing district court to “address conditions that exist at the time of the hearing”).

Further, the county’s efforts must also be “realistic under the circumstances.” Minn. Stat. § 260.012(h)(8); (“The nature of the services which constitute reasonable efforts depends on the problem presented.”).

The district court also found that father’s “volatile mental health impairs his ability to parent.” While father’s mental health alone does not warrant a termination of parental rights, d 886, 892 (Minn. 1996), father’s failure to address his mental-health concerns affected his ability to care for the children and prevented him from correcting the conditions that led to their removal.

(using a parent’s prior history as context for existing circumstances); (observing demonstrated patterns of prior behavior during a termination proceeding).

We decline to adopt this rigid rule, as it does not comport with the legislature’s direction that reasonable efforts should be “tailored to the individualized needs of the child and the child’s family.” Minn. Stat. § 260.012(h)(2); (holding “[t]he nature of the services which constitute ‘reasonable efforts’ depends on the problem presented”).

(“If [appellant] cannot care for himself on a sustained basis, it follows that he cannot care for a child.”).

et back on track with [her case plan requirements] to be able to reunify with her children.” This testimony supports the district court’s finding that the county attempted to provide services and assistance to the family “throughout this case.” We recognize that “[t]he nature of the services which constitute ‘reasonable efforts’ depends on the problem presented.”

She asserts that a district court should rely “not primarily on past history, but to a great extent upon the projected permanency of the parent’s inability to care for his or her child.” (quotations omitted).

To determine that this statutory basis exists, the “district court must also determine that, at the time of termination, the parent is not presently able and willing to assume [their] responsibilities and that the condition will continue for the reasonably foreseeable future .” A.M.C., d at 655

contends that it is unclear whether the county made reasonable efforts with respect to her “need for respite care, daycare, [and] after-school activities.” “The nature of the services which constitute ‘reasonable efforts’ depends on the problem presented.”

see also Minn. Stat. § 260C.301, subd.

(stating, on review of an order terminating parental rights, that “the evidence must address conditions that exist at 12 the time of the hearing”).

However, we also “closely inquire into the sufficiency of the evidence to determine whether it was clear and convincing.” see also In re 8 Welfare of S.Z., (stating that appellate courts “exercise[] great caution in termination proceedings, finding such action proper only when the evidence clearly mandates such a result”).

“[P]rovision of reasonable efforts must be evaluated by the court in every case.”

The supreme court has stated that "'the provision of reasonable efforts must be evaluated by the court in every case."' TR., d at 664 ().

fforts requires the district court to consider whether services to the child and family were: “(1) relevant to the safety and protection of the child, (2) adequate to meet the n eeds of the child and family , (3) culturally appropriate, (4) available and accessible, (5) consistent and timely, and (6) realistic under the circumstances.” Minn. Stat. § 260.012(h) (2020)

The district court may consider the past, but the primary consideration should be “the projected permanency of the parent’s inability to care for his or her child.” (quotation and citation omitted).

d 886, 893 (Minn. 1996).

d 886, 893 (Minn. 1996).