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

Summary

The court affirmed the termination of Dara's parental rights, holding that the superior court had sufficient grounds to find that her mental illness, together with specific conduct, placed Paxton at substantial risk, that OCS made reasonable reunification efforts, and that she had been given a reasonable time to remedy the conditions. The court held that a post-termination reinstatement proceeding remains available before adoption or legal guardianship and adopted a clear-and-convincing-evidence standard requiring proof of rehabilitation, parenting capability, and the child's best interests. Because the superior court's best-interests findings were insufficiently developed, the court remanded for clarification while retaining jurisdiction.