Philip J., Appellant v. State of Alaska, Department of Health & Social Services, Office of Children's Services…

Summary

The court affirmed the adjudication of Philip's seven children as children in need of aid. It held that due process was satisfied because the State gave Philip advance and repeated notice that it would seek adjudication findings, he had an opportunity to respond to the evidence, and he showed no actual prejudice. The court also held that Philip waived any right to a closing argument by never requesting one, and therefore found no cumulative error. Justice Winfree, dissenting, would have reversed because the trial court did not timely notify Philip that it would decide adjudication rather than probable cause.