In the Matter of the Welfare of the Child of: B.D.D. and D.A.A., Parents

Summary

The court held that a parent may move under the governing juvenile-protection rule to withdraw an admission to a termination-of-parental-rights petition at any time when withdrawal is necessary to correct a manifest injustice, even after the termination order becomes final. The court further held that an evidentiary hearing is required only if the motion and supporting materials make a prima facie showing of manifest injustice and the necessity of withdrawal. Because the district court struck the motion without making that threshold determination, the court reversed and remanded.