In Re: Parental Rights as to R.a.s.

Summary

The Nevada Supreme Court reversed an order terminating Shianna G.'s parental rights because none of the four parental-fault grounds found by the district court was supported by substantial evidence. The court held that Shianna rebutted the abandonment presumption, that leaving the child with a caregiver who provided proper care did not establish neglect or unfitness, and that her efforts were not merely token when the other parent impeded contact. The court also directed district courts to scrutinize privately initiated termination petitions carefully because they differ from state-initiated proceedings.