In Re Lukas K.

Summary

The court held that an incarcerated parent was not constitutionally entitled, under the particular circumstances, to a trial transcript and continuance to recall witnesses and respond to evidence in a parental-rights termination proceeding. Applying the procedural due process balancing test, the court concluded that although the parent’s interest was fundamental, the requested procedures would not have meaningfully reduced the risk of an erroneous termination because he identified no specific additional material evidence or arguments. The judgment affirming termination of parental rights was affirmed.