Jessie D. v. Department of Child SafetyAnnotate this Case
The Supreme Court affirmed the order of the juvenile court terminating the parent-child relationship of Father to his four children, holding that while the juvenile court misapplied two factors set forth in Michael J. v. Arizona Department of Economic Security, 196 Ariz. 246 (2000), substantial evidence existed to support the termination.
After a hearing, the juvenile court found that Father's incarcerative sentence was of sufficient length to deprive the children of a normal home for a period of years and that termination of Father's parental rights was in the children's best interests. The court of appeals affirmed, concluding that the juvenile court did not abuse its discretion in evaluating the Michael J. factors. The Supreme Court affirmed, holding (1) the juvenile court misapplied the first two Michael J. factors; (2) the juvenile court did not abuse its discretion in determining that Father's sentence was of sufficient length to deprive the children of a normal home for a period of years; and (3) reasonable evidence supported the juvenile court's best-interests finding.