Steve H. v. State of Alaska, Department of Health & Social Services, Office of Children's Services

Summary

The court affirmed termination of Steve H.'s parental rights because the superior court did not clearly err in finding that he abandoned his son, that returning the child to his custody would likely cause serious emotional or physical harm, and that termination was in the child's best interests. The court held that the statutory abandonment criteria, rather than a separate common-law abandonment test, governed the case. The court also upheld findings that Steve failed to remedy conduct involving prolonged absences, inconsistent visitation and communication, and refusal to comply meaningfully with drug-testing and case-plan requirements.