"The failure to remedy the conditions which led to the removal need not be willful." In re Navada N., 498 S.W.3d 579, 606 (Tenn. Ct. App. 2016); see also, e.g., In re B.D.M., No. E2022-00557-COA-R3-PT, 2023 WL 3019005, at *11 (Tenn. Ct. App. Apr. 20, 2023). "A parent's continued inability to provide fundamental care to a child, even if not willful, . . . constitutes a condition which prevents the safe return of the child to the parent's care."

A petitioner seeking to terminate a parent's rights pursuant to Tenn. Code Ann. § 36-1-113(g)(2) need not put on proof of DCS's reasonable efforts. In re B.D.M., No. E2022-00557-COA-R3-PT, 2023 WL 3019005, at *5 (Tenn. Ct. App. Apr. 20, 2023). Indeed, the only termination ground requiring proof of DCS's reasonable efforts is the ground for abandonment by failure to provide a suitable home.

"The failure to remedy the conditions which led to the removal need not be willful." In re Navada N., 498 S.W.3d 579, 606 (Tenn. Ct. App. 2016); see also, e.g., In re B.D.M., No. E2022-00557-COA-R3-PT, 2023 WL 3019005, at *11 (Tenn. Ct. App. Apr. 20, 2023). "A parent's continued inability to provide fundamental care to a child, even if not willful, . . . constitutes a condition which prevents the safe return of the child to the parent's care."

In re Joseph D., No. M2021-01537-COA-R3-PT, 2022 WL 16848167, at *19 (Tenn. Ct. App. Nov. 10, 2022) (citing In re David J.B., No. M2010-00236-COA-R3-PT, 2010 WL 2889265, at *7 (Tenn. Ct. App. July 23, 2010)). In re B.D.M., No. E2022-00557-COA-R3-PT, 2023 WL 3019005, at *14 (Tenn. Ct. App. Apr. 20, 2023).