Interest of M.S.H. and P.S.H.

Summary

The North Dakota Supreme Court dismissed K.S.H.’s appeal from an order denying her motion to reform a request for district court review in a termination of parental rights proceeding. The court held that the appeal was untimely because it was filed more than 30 days after the final order terminating parental rights. The court therefore lacked jurisdiction to consider the appeal.

Holdings

1. The Supreme Court lacks jurisdiction to consider an appeal from an order terminating parental rights when the appeal is not filed within the mandatory 30-day period.
2. A motion to reform a document filed after the appeal deadline does not extend the time for appeal, create an exception to the mandatory deadline, or provide a means to collaterally attack a final termination order.

Questions Presented

1. Whether the Supreme Court had jurisdiction over an appeal filed more than 30 days after an order terminating parental rights became final.
2. Whether a post-deadline motion to reform a request for district court review could extend the time for appeal, create an exception to the mandatory appellate deadline, or permit a collateral attack on the termination order.

Disposition

dismissed