Widick v. State

Summary

The Oklahoma Supreme Court held that appellate review of parental-rights-termination decisions must determine whether the trial court's findings are supported by clear-and-convincing evidence, rather than applying an any-competent-evidence standard. Relying on the constitutional protections recognized in Santosky v. Kramer, the court concluded that a less stringent appellate standard could undermine the required burden of proof. The case was remanded to the Court of Civil Appeals for reconsideration under the proper standard and resolution of the remaining issues.

Holdings

1. The any-competent-evidence standard is insufficient under the Fourteenth Amendment for appellate review of findings terminating parental rights. Appellate review must determine whether the trial court's findings are supported by clear-and-convincing evidence.

Questions Presented

1. Whether the any-competent-evidence standard of appellate review in a parental-rights-termination proceeding satisfies the Fourteenth Amendment.
2. Whether appellate courts must review the record to determine whether parental-rights-termination findings are supported by clear-and-convincing evidence.

Disposition

remanded