The Utah Court of Appeals reversed a dependency adjudication because a noncustodial father’s lack of a prior relationship did not establish inability to care for his child.
The Utah Supreme Court held that it could review a post-remand parental-rights judgment but not errors predating the first appeal, then affirmed termination as strictly necessary.
The Utah Supreme Court held that terminating parental rights to facilitate an adoption requires a strictly necessary analysis, while affirming because the district court’s omission was harmless.
Applying Ross v. Kracht, the Utah Supreme Court affirmed that terminating an incarcerated father’s rights was strictly necessary to protect four children’s stability and permit their stepfather’s adoption.