Termination of Parental Rights

82.08.c Adjudication Hearing-Need to Present Evidence 7B-1107, 7B-1109(e)

In Re E.F.C.K. and C.F.W., COA05-157, Don Willey for appellant-mother
The trial court erred during the adjudicatory phase of the TPR by accepting trial counsel's stipulation to a factual basis for termination without taking evidence.
COA Opinion

In Re N.B. et al., COA08-1082, Richard Croutharmel for appellant-mother
The trial court erred when it relied solely on documentary evidence and received no sworn testimony at the TPR adjudication hearing.
COA Opinion