In re A.H.
In re A.H., 2021 UT App 57 (Pohlman, J.)
Children were removed from Father’s care after a report of domestic violence. Father participated in services for over a year, but the juvenile court then terminated his parental rights. The Utah Court of Appeals affirmed, holding:
- On Father’s claims of ineffective assistance of counsel, although trial counsel may have made some questionable decisions that amounted to deficient performance, Father failed to analyze prejudice as to each of the five statutory grounds on which the juvenile court found termination was warranted. Similarly, although Father challenged one ground as insufficient to support termination, he failed to challenge the other four statutory grounds, which were independent alternative bases for the termination decision.
- Given Father’s lack of progress and overall untimely efforts, the court of appeals could not say that DCFS’s services were unreasonable under the circumstances.