The Appellate Group

In re R.G.

In re R.G., 2023 UT App 144 (Christiansen Forster, J.)

Child Welfare

Father appealed the termination of his parental rights, arguing termination was not strictly necessary because placement with Aunt in another state was possible. The Utah Court of Appeals affirmed, holding:

  • The juvenile court’s best interest analysis adequately foreclosed Aunt as an option because Child had never met Aunt, Aunt has never requested visits with Child, and Child has no familial relationship with Aunt.
  • Practice tip: A placement with a sibling or half-sibling is a kinship placement.

Read the full court opinion