In Re Shaolin P. et al.

The juvenile court terminated Father’s parental rights on the grounds of abandonment by willful failure to provide support and substantial noncompliance with the permanency plans. Because we have concluded that the Department of Children’s Services failed to establish, by clear and convincing evidence, that Father’s failure to pay support was willful or that the Department’s efforts to help Father find housing were reasonable, we reverse the juvenile court’s decision.