Mets v. State, Department of Family Services
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The Supreme Court affirmed the order of the district court terminating Mother's parental rights, holding that even if the district court erred in admitting Mother's physician's testimony and a related 2011 medical record, Mother was not prejudiced and the error was harmless.
The jury found clear and convincing evidence for termination on grounds on two separate statutory grounds. Mother appealed, arguing that the district court abused its discretion when it admitted privileged evidence through her physician's testimony and an associated medical record. The Supreme Court affirmed, holding (1) there was ample evidence without the physician testimony and associated medical record to show that Mother was unfit to have custody and control of the child as required by Wyo. Stat. Ann. 14-2-309(a)(v); and (2) even assuming the testimony and medical record were privileged and the district court erred in admitting them, the error was harmless.
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