In the Interest of M.M.C., I.R.C., W.A.C., W.L.C., Children

Summary

The North Dakota Supreme Court affirmed orders terminating the parental rights of the father and mother of four children. The court concluded the juvenile court’s findings were not clearly erroneous and summarily affirmed based on multiple independent statutory grounds.

Holdings

1. The juvenile court’s findings supporting termination of the parents’ parental rights were not clearly erroneous.
2. Summary affirmance was appropriate because the juvenile court’s findings were not clearly erroneous and the case fell within the applicable summary-affirmance rule.

Questions Presented

1. Whether clear and convincing evidence supported findings that deprivation was likely to continue and that the children would likely suffer harm absent termination of the parents’ parental rights.
2. Whether reasonable efforts had been made to prevent the children’s removal or continued placement outside the parental home and to reunify the family.
3. Whether the parents subjected the children to aggravated circumstances under N.D.C.C. § 27-20-02(3).
4. Whether the juvenile court’s termination order should be summarily affirmed.

Disposition

affirmed