## Facts

- A.C. was born on August 10, 1985.
- When A.C. was about two months old, his father, R.R., voluntarily placed him in emergency care with the District of Columbia Department of Human Services (DHS) because the mother could not be located.
- A.C. was placed first in an infant home, then interim foster care, and in July 1986 was placed with a foster family where he remained through the termination hearing in November 1990.
- R.R. visited A.C. once during a brief hospitalization in October 1985 and had no meaningful contact thereafter.
- DHS made repeated efforts over several years to locate and involve R.R., including contacting relatives and checking shelters, hospitals, jails, and the morgue; at least one visit was arranged that R.R. did not attend.
- A court order in June 1988 granted R.R. reasonable visitation rights, but he did not use them.
- When A.C. was five, the guardian ad litem petitioned to terminate both parents’ rights under D.C. Code § 16-2353; the trial court terminated both.
- The mother did not appeal; R.R. appealed the termination of his parental rights.

## Issues

1. Whether due process required DHS to prove “reasonable efforts” to reunite R.R. with A.C. as a condition precedent to terminating parental rights.
2. Whether the trial court was required to apply a presumption favoring a fit biological parent in deciding whether to terminate R.R.’s rights.
3. Whether clear and convincing evidence supported termination as in A.C.’s best interests under D.C. Code § 16-2353.

## Decision

- The District of Columbia Court of Appeals affirmed the order terminating R.R.’s parental rights.
- The court held that DHS reunification efforts are a relevant consideration, but agency shortcomings do not bar termination when termination is otherwise in the child’s best interests.
- The court rejected R.R.’s claim to a parental preference because he failed to develop a parental relationship with A.C. and did not act on his “opportunity interest.”
- The court found the evidence clear and convincing that termination served A.C.’s best interests, given the child’s long-term stable foster placement, bonding with caretakers, and the availability of adoption.

## Legal Principles

- Under D.C. Code § 16-2353, termination of parental rights requires clear and convincing evidence that termination is in the child’s best interests, evaluated under statutory factors including stability, continuity of care, bonding, time in foster care, and adoption prospects.
- A public agency’s efforts to reunify the family are a factor in the best-interests analysis, but they are not an independent element the petitioner must prove in every termination case.
- A biological parent who does not come forward to assume meaningful parental responsibility may have a diminished claim to any presumption favoring natural parents; an unwed father must act on the opportunity to form a parental relationship to claim heightened constitutional protection.

## Conclusion

The court affirmed termination of the father’s parental rights because the child’s best interests—especially long-term stability, established attachment to foster caretakers, and a realistic path to adoption—outweighed the father’s biological tie and any asserted deficiencies in reunification efforts.


In re A.C., 597 A.2d 920 (D.C. 1991)