Task: Text Completion
Input (English): is in Arteria H.’s best interest. Instead, Father asserts that his parental rights should not be terminated because DCS did not make reasonable efforts to place Arteria H. with a relative and because of ineffective assistance of counsel in the Juvenile Court proceeding. After reviewing his brief, it is clear to this Court that all of Father’s allegations of error involve the alleged lack of reasonable efforts on the part of DCS or errors which occurred during the dependency and neglect proceeding. However, the two grounds upon which Father’s parental rights were terminated, do not require reasonable efforts on the part of DCS or require a previous finding of dependency and neglect. See e.g., In re C.A.H., No. M2009-00769-COA-R3-PT, 2009 WL 5064953, at *4 (Tenn.Ct.App. Dec. 22, 2009)(<HOLDING>); In re G.L.T., No. M2008-00582-COA-R3-PT, 2008 
 Holding statements: (A) recognizing majoritys failure to address impact of mothers incarceration upon circuit courts decision to terminate her parental rights (B) holding that dcs did not have to provide reasonable efforts when petitioning to terminate parental rights based upon the ground of abandonment (C) holding in a termination of parental rights case that as a question of law the trial courts ruling that the facts of this case sufficiently support the termination ground of willful abandonment are reviewed de novo with no presumption of correctness (D) recognizing the fundamental liberty interest a parent has in his or her child and concluding that the state must provide a parent with fundamentally fair procedures including a clear and convincing evidentiary standard when seeking to terminate parental rights (E) holding that the obligation does not terminate upon death
Output (English): (B)