D.M. v. Department of Children and Families
In consolidated appeals from a judgment terminating both parents' rights, the Third District affirmed as to the father and found competent substantial evidence supported termination as to the mother, who had voluntarily surrendered her rights mid-adjudicatory hearing. The court nonetheless reversed and remanded for entry of an amended final judgment because, under Florida Rule of Juvenile Procedure 8.520(c), the trial court must make findings of fact specifying the act or acts causing termination, not merely rely on the voluntary surrender itself.
Key facts
- D.M., a child, was the subject of consolidated dependency proceedings against both parents brought by the Department of Children and Families seeking termination of parental rights.
- At the adjudicatory hearing, the father's parental rights were terminated; the mother voluntarily surrendered her parental rights mid-hearing, and the trial court entered a final judgment of termination based on the surrender.
- +2 more key facts with a free trial
Why it matters
The opinion gives Third District practitioners a clear, citable rule that a TPR final judgment premised on voluntary surrender is facially deficient unless it contains findings specifying the acts supporting termination… — full analysis with a trial
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