Sabrina v. v. State of Alaska, Department of Health and Social Services, Office of Children's Services

Summary

The court affirmed the denial of Sabrina's motion for reconsideration and the termination of her parental rights. It assumed without deciding that the superior court had discretion to permit withdrawal of a relinquishment after the statutory ten-day period, but held that declining to do so was not an abuse of discretion because the relinquishment expressly made withdrawal timely only within ten days and provided merely for notice if the planned adoption failed. The court also declined to reach Sabrina's direct challenge to the child's best interests because she had not validly withdrawn or otherwise attacked the relinquishment. The opinion notes that trial courts must make adequate best-interests findings to permit meaningful appellate review.