In a child protection motion concerning a newborn apprehended at birth, the parents sought return of the child under a temporary supervision order and the society sought continued temporary society care with prejudice.
The court applied the statutory test under the Child, Youth and Family Services Act, 2017 and found reasonable grounds to believe the child would be at risk of harm if placed with the parents, based on longstanding parental alcohol addiction, repeated domestic violence incidents, unresolved parenting-capacity concerns, and the parents’ failure to address prior protection concerns arising in proceedings involving another child.
The court further held that supervision terms would not adequately manage the risk because the parents denied their addiction issues, had not meaningfully engaged in treatment or recommended services, and had not demonstrated reliable compliance or a workable care plan.
The least disruptive placement consistent with the child’s protection was continued temporary society care, with parental access at the society’s discretion subject to a minimum schedule.