RH v. State
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The Supreme Court dismissed this case arising from an ongoing juvenile court action involving three minor children and their mother, holding that the juvenile court lost jurisdiction over one of the children, BG, when BG turned eighteen years old because the requirements of Wyo. Stat. Ann. 14-3-431(b) were not met.
When BG was fifteen, the juvenile court placed Mother's three children in the custody of the Department of Family Services and adjudicated Mother neglectful. While the Department began pursuing a permanency plan of adoption/guardianship for the three children, BG turned eighteen. The juvenile court, however, continued to issue orders as though the Department retained custody over BG. Mother argued that, under section 14-3-431(b), a review hearing should have taken place six months before BG's eighteenth birthday for the court to retain jurisdiction over her, and because a review hearing did not take place the court lacked jurisdiction over BG. The juvenile court held that its jurisdiction over BG had not terminated. The Supreme Court disagreed and dismissed this action, holding that the juvenile court's jurisdiction over BG terminated when she reached eighteen years of age because the court did not fulfill the requirements of section 14-3-431(b).
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