R.D.S. v. Department of Children and Families
In consolidated dependency/TPR appeals involving a diabetic child, the Third DCA affirmed the adjudications of dependency and the denial of the petition to terminate parental rights, finding competent substantial evidence supported the trial court's refusal to find 'egregious conduct.' The court held the trial judge erred by allowing a non-party hospital's attorney to attend the statutorily confidential TPR trial over the parents' objection (though harmless), and granted certiorari to quash the portion of the order requiring the parents' mental health evaluation to assess for Munchausen Syndrome by Proxy, a condition never mentioned or alleged at trial.
Key facts
- R.D.S. (parent) appealed the trial court's adjudication of dependency and denial of petition to terminate parental rights in a consolidated dependency/TPR case involving a diabetic child.
- The trial court found the parent failed to follow medical instructions and ordered the parent to undergo a psychological evaluation for Munchausen Syndrome by Proxy, a condition never alleged or presented at trial.
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Why it matters
The opinion supplies two reusable rules: (1) a litigant's objection to third-party counsel's presence in a statutorily closed TPR proceeding must be sustained — DCF's non-objection does not open the courtroom; and (2)… — full analysis with a trial
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