In Re: Adoption of Angela E, et al.
Lower Court Summary
This appeal involves a petition to terminate parental rights that was filed in 2005. At the
hearing, the Father consented to the termination of his parental rights, so the trial court
entered an order terminating his parental rights without making findings of fact and
conclusions of law regarding grounds for termination and the children’s best interest. Father
subsequently challenged the trial court’s order on appeal, and the Supreme Court reversed
and remanded for the trial court to hold a new hearing and prepare an order with the requisite
findings. On remand, the trial court found that Father had not abandoned the children by
willfully failing to visit them or by willfully failing to support them, and therefore it declined
to terminate his parental rights. We reverse and remand for further proceedings.