In re Ivory W.

Summary

The court affirmed the termination of the respondent mother's parental rights, holding that denying her fourth continuance request did not violate federal or state due process and was not an abuse of discretion. Her inability to testify without risking self-incrimination was not an unconstitutional penalty because the termination judgments were based on independent clear and convincing evidence, no adverse inference was drawn, and she could present other evidence. The court also declined to require a categorical continuance whenever related criminal charges are pending, preserving trial-court discretion to balance competing interests.