New Jersey Division of Youth and Family Services, Plaintiff-Respondent v. R.D., Defendant-Appellant. in the Matter…

Summary

The Supreme Court held that findings from a Title Nine abuse or neglect proceeding cannot be given collateral estoppel effect in a later Title Thirty guardianship or termination of parental rights proceeding unless the parties received clear notice that the higher clear‑and‑convincing evidence standard would apply and appropriate accommodations were made. Accordingly, the Title Thirty court must make independent findings on the first prong of the best‑interests of the child test. The Court reversed the Appellate Division and remanded for a new evidentiary trial on that issue.