Arizona Supreme Court

Marianne N. v. dcs/o.N./i.T./a.G.

September 25, 2017

Summary

The court held that the juvenile court could apply Rule 64(C) to proceed with a termination adjudication when a parent failed without good cause to attend a pretrial conference. The rule and the governing statute could be harmonized because the statute did not restrict the termination hearing to a previously scheduled adjudication hearing or prohibit converting a scheduled pretrial proceeding into the adjudication. The court therefore found no separation-of-powers violation and affirmed the termination of Marianne's parental rights.