In re Ivory W.

Summary

The court affirmed the judgments terminating the respondent mother's parental rights, holding that denying her fourth request to continue the termination trial while related federal criminal charges were pending violated neither federal nor state due process. The court concluded that her inability to testify after invoking the privilege against self-incrimination was not a sufficiently severe penalty to constitute unconstitutional compulsion, and that the trial court reasonably balanced her interests against the children's need for permanency and the other circumstances of the case. The court also declined to adopt a categorical rule requiring continuances whenever a related criminal proceeding is pending.