Sandra R./sergio C. v. dcs/m.R./f.M./j.M.

Summary

The court held that, when parental rights are terminated under A.R.S. § 8-533(B)(2) based on abuse or neglect of one child, the juvenile court must determine during the initial parental-unfitness inquiry whether clear and convincing evidence shows that the parent poses a risk of harm to the other children at issue. The court rejected placing that risk determination in the best-interests inquiry, affirmed the termination of the parents' rights to the non-abused children, and vacated the lower appellate opinion in part.