Unfortunately once the rights have been terminated it is very hard to get that ruling overturned. However, it can be done but your daughter would have to show that she ‘substantially complied’ with the *original* plan they put into place with/for your daughter. Hopefully that plan identifies such and such steps that if completed will lead to reunification with her baby. Can you tell me if the first plan (or any others that followed) identified the goal as Katie going home?
Here is a sad yet happy case of a mother who had her children taken away, remedied everything the state asked her to yet still in the end her rights to her baby son were terminated. Something about how the mom never really bonded with the baby, I wonder if the canceled visitations and withdrawal of visitation privileges (state to mother) had anything to do with the then toddlers lack of connection with his bio mom despite the mothers continual and persistent attempts to keep the bond strong. Hmmmm
http://kidjacked.com/legal/va_tpr_appeals_case.asp <~~ the case in question, Kidjacked may be a great resource for you also.