In the recent CINA (Children In Need of Assistance) case of In re Joy D., the Maryland Court of Special Appeals held that a parent can permanently lose their right to regain custody if they persistently fail to take the necessary steps in working towards reunification with their child. In the Joy D. case, the mother had a history of abusing and neglecting her child. She also suffered from severe psychological problems. Nonetheless, her refusal to cooperate with social services in their treatment and reunification efforts ultimately led to her permanently losing all custody rights.
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