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In this termination of parental rights appeal, the
appellate court reiterated prior holdings that the trial court may
consider evidence pre-dating the filing of a neglect petition if
that evidence is relevant to an understand of the family dynamics
and the respondent's ability to safely parent a child. Here, the
appellate court rejected the respondent mother's claims that the
trial court gave undue weight to information regarding DCF's prior
involvement with her other children in considering the adequacy
of DCF's efforts to reunify her with Christopher as well as whether
the respondent had failed to rehabilitate as a parent. The appellate
court affirmed the trial court's findings that the Department made
reasonable efforts to reunify her with her son and that she had
failed to rehabilitate within the meaning of the statute.
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