D.M., a juvenile, and R.M., the Father v. Department of Children and Families
In consolidated appeals from a judgment terminating both parents' rights, the Third DCA affirmed as to the father and found competent substantial evidence supporting termination as to the mother, who had voluntarily surrendered her rights mid-hearing. The court nevertheless reversed and remanded for entry of an amended final judgment because, under Florida Rule of Juvenile Procedure 8.520(c), the judgment must contain findings of fact specifying the act or acts causing termination — not merely the voluntary surrender itself.
Key facts
- Juvenile D.M. and father R.M. appealed from a trial court judgment terminating both parents' parental rights in a dependency case brought by the Department of Children and Families.
- The mother voluntarily surrendered her parental rights during the adjudicatory hearing, while the father contested termination; the trial court accepted the mother's surrender and terminated both parents' rights.
- +2 more key facts with a free trial
Why it matters
This is the Third District's first express adoption of the Fifth District's reading of rule 8.520(c), giving dependency practitioners a clear appellate hook where a termination judgment rests solely on a parent's… — full analysis with a trial
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