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

Summary

The court affirmed the termination of Sarah A.'s parental rights, holding that the superior court's partiality-related conduct concerning substance-abuse evidence did not constitute structural error or violate due process. Although the superior court improperly relied on extrajudicial information and adopted an argumentative tone when questioning witnesses, the challenged conduct affected at most one termination ground, while unchallenged domestic-violence and mental-illness grounds independently supported termination. Remand would therefore have had little probable value and would have unnecessarily delayed permanency for the child.