Claudio P. v. Alaska
Annotate this CaseClaudio P. was incarcerated before his daughter Iris was born and was likely to remain incarcerated for a significant portion of Iris's childhood. Iris was taken into State custody in June 2010 due to her mother's substance abuse and unsafe conditions in her home. Claudio's mother requested that Iris be placed with her, but she was unable to maintain stable housing. Claudio provided the name of his father, who lived in South Dakota, as another placement option. OCS requested home studies under the Interstate Compact on the Placement of Children for each of Claudio's parents. Both home studies came back with positive recommendations shortly before the termination trial. Following the trial, the trial court terminated Claudio's parental rights to Iris and noted that Iris's permanent placement would be determined at a subsequent hearing. Claudio argued that the trial court erred by terminating his rights because OCS should have taken more action to place Iris with one of his parents. After its review, the Supreme Court concluded that OCS's investigation of Claudio's placement request was reasonable and timely, and that each of the trial court's challenged findings was supported by substantial evidence.
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