In re R.D.
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The Supreme Court affirmed in part and vacated in part the judgment of the district court determining that termination of Father's parental rights was not in the child's best interests and dismissing Bethany Christian Services' petition to terminate parental rights, holding that a challenged portion of one of the trial court's findings of fact was erroneous.
Specifically, the Supreme Court held (1) the trial court’s admission of the guardian ad litem’s report during the dispositional stage of the termination proceeding without allowing the child's guardian ad litem to be cross-examined about the report was not an abuse of discretion; and (2) the trial court’s written order contained a key finding of fact that lacked evidentiary support in the record and could be read as reflecting an inappropriate bias against adoption, and this inappropriate finding was prejudicial.
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