I've been looking for this all day. Finally found it.
Florida DCF Grounds for Termination of Parental Rights:
I think mother meets several of the criteria.
So, basically, she may have a mental illness or deficiency, which isn't reason to terminate.
But, due to the fact that DCF has issued them a case plan in the past, which they obviously did not choose to follow after the file was closed, she could lose her rights. If the department decides that she had the ability and opportunity to stop Shannon from being harmed, she could lose her rights.
Link also states that all the state is required to do in cases where they intend to immediately file to terminate is to provide the same services in the plan established until the termination. There is no plan in place, mother is entitled to nothing.
I have to know this to sleep. Shannon really did need to be rescued, and now I think she needs to be sent with other family, and she can see her mother at holidays in a supervised environment. Safe, but still in contact. Everybody wins.