In re Ivory W.

Summary

The court affirmed the termination of the respondent mother's parental rights, holding that denying a continuance pending resolution of related criminal charges did not violate federal or state due process. The respondent's inability to testify after invoking the privilege against self-incrimination was not an unconstitutional penalty because the termination judgments rested on independent clear and convincing evidence, no adverse inference was drawn, and she could present other evidence. The court also held that the trial court acted within its discretion and declined to impose a categorical supervisory rule requiring continuances in such cases.