In re B.J.T.H.
Annotate this CaseIn 2012, the district court terminated Mother’s parental rights to her twins, finding that Mother had received counseling and subsequently executed a knowing and voluntary relinquishment of her rights. The Supreme Court remanded for the district court to make a determination of whether Mother had received the required relinquishment counseling or whether good cause existed to waive the requirement. On remand, the district court found that the counseling received by Mother satisfied the counseling provisions of Mont. Code Ann. 42-2-409. The Supreme Court affirmed, holding (1) there was substantial evidence to support the district court’s finding that, before signing an affidavit relinquishing her parental rights, Mother received counseling required by section 42-2-409; and (2) a deficiency in the reporting requirement was harmless.
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