Penn P. Jr. v. State of Alaska, Department of Health & Social Services, Office of Children's Services

Summary

The Alaska Supreme Court affirmed the termination of Penn’s parental rights. It held that the superior court erred by relying on unadmitted drug-treatment records, but the error was harmless because other admitted evidence supported the findings and the records added little. The court also rejected Penn’s ineffective-assistance claim and declined to adopt his proposed appellate screening framework, while clarifying that such claims in CINA cases will continue to be reviewed as presented on direct appeal.