In re A.N.H.
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The Supreme Court remanded this termination of parental rights matter for further proceedings, holding that the findings of fact supported by clear, cogent and convincing evidence in the record were insufficient to support the trial court's conclusion that Father's parental rights in his daughter Annie were subject to termination.
Petitioners sought to terminate Father's parental rights based on the fact that he failed some of the drug screens he admitted to between 2018 and 2020 and failed to submit to others. The trial court, however, found Father to have completed a required substance abuse assessment, completed twenty hours of substance abuse treatment, attended visits with his daughter, and completed a parenting program, among other things. The trial court terminated Father's parental rights in his daughter. At issue on appeal was whether the findings of fact that were supported by clear, cogent and convincing evidence in the record were sufficient to support the trial court’s conclusion that grounds existed to terminate Father’s parental rights for neglect and failure to make reasonable progress. The Supreme Court remanded the matter, holding that the trial court's findings of fact were insufficient to support its termination decision.
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