In re P.M.
In re P.M., 2025 UT App 154, 2025 UT App 155 (Christiansen Forster, J.)
Child Welfare
The Utah Court of Appeals held:
- Mother had invited any error related to the delayed adjudication hearing when her counsel repeatedly urged the juvenile court to delay the hearing until after the UCCJEA and ICPC issues were resolved.
- The court of appeals reversed the dependency adjudication as to Father, finding that the juvenile court’s factual findings were inadequate to establish that child was without care from Father.
- Practice tip: When there is an emergency removal of a child from one parent due to unforeseen circumstances (such as involuntary commitment), the other parent’s initial unavailability and temporary absence is insufficient for the court to make a dependency finding unless the parent was informed of the removal and failed to provide timely care.