In the Interest of D. H. et al., Children
A juvenile court found two children dependent because their mother had an untreated mental health condition, and the Court of Appeals affirmed. The Supreme Court of Georgia held that a diagnosis alone did not establish the statutory ground the juvenile court used. The law required evidence of a medically verified deficiency whose duration or nature rendered the mother unable to provide adequate care. The record did not support that connection, so the lower courts could not rely solely on her condition to find neglect and dependency. The Supreme Court vacated the appellate decision and directed a remand to the juvenile court to reconsider dependency on the whole record. It left open whether other evidence or statutory grounds might support a dependency finding. The decision requires proof of effects on parenting, not an inference from mental health status alone.
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