In re J.D.O.

Summary

The Court affirmed the termination of the mother's parental rights. It held that the trial court had subject matter jurisdiction despite not making express UCCJEA jurisdictional findings, properly considered the juvenile case file, and made sufficient findings to establish prior neglect and a likelihood of future neglect based principally on continuing substance-abuse concerns. The Court declined to address the other statutory grounds because one ground supported termination and rejected extending cumulative-error review to this civil termination proceeding.