In re Dynastie D.

Summary

The court held that the out-of-state placement statute creates an implied, rebuttable presumption favoring in-state placement, which the party seeking an out-of-state placement must overcome by proving good cause by a preponderance of the evidence. Good cause is legally distinct from the child's best interests and requires consideration of the placement's effect on parental reunification efforts. Because the trial court applied only the best-interests standard and did not address the presumption or reunification interests, the judgment was reversed and remanded for further proceedings.