Niland v. State, ex rel. Department of Family Services
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The Supreme Court reversed the judgment of the district court terminating Appellant's parental rights, holding that the district court violated Appellant's due process rights when it determined the best interests of the child without first conducting an evidentiary hearing.
The district court found that the Department of Family Services established statutory grounds for termination by clear and convincing evidence. On appeal, Appellant argued that he was not given an opportunity to be heard on the question of whether termination was in the child's best interests. The Supreme Court held (1) neither the termination statutes nor Wyoming case law require a separate hearing to determine the best interests of the child; but (2) Appellant's due process rights were violated when he was deprived of the opportunity to be heard on the question of best interests.
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