87372-5•In The Matter Of The Parental Rights To R.j.c.s.
Texte intégral
IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE In Re the Parental Rights of: R.J.C.S., Minor Child. No. 87372-5-I DIVISION ONE UNPUBLISHED OPINION P ER CURIAM — The father of R.J.C.S. appeals the order terminating his parental rights. The Department of Children, Youth, and Families (Department) concedes errors: (1) the record does not support a finding that it made the “active efforts” to provide services as required by the Indian Child Welfare Act (25 U.S.C. § 1912(d)) and the Washington Indian Child Welfare Act (RCW 13.38.130(1)); and (2) the termination petition did not provide the father with constitutionally sufficient notice of an alleged parenting deficiency that formed the basis for terminating his parental rights. See In re Dependency of A.M.M., 182 Wn. App. 776, 791, 332 P.3d 500 (2014). The Department also acknowledges that it failed to offer services to address the alleged parenting deficiency as necessary to meet its burden under RCW 13.34.180(1)(d). We accept the Department’s concessions. Accordingly, we reverse the order terminating the father’s parental rights and remand for further proceedings consistent with this opinion.
No. 87372-5-I/2 -2- Reversed and remanded. FOR THE COURT:
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FILED 12/8/2025 Court of Appeals Division | State of Washington IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE In Re the Parental Rights of: No. 87372-5-| R.J.C.S., DIVISION ONE Minor Child. UNPUBLISHED OPINION PER CURIAM — The father of R.J.C.S. appeals the order terminating his parental rights. The Department of Children, Youth, and Families (Department) concedes errors: (1) the record does not support a finding that it made the “active efforts” to provide services as required by the Indian Child Welfare Act (25 U.S.C. § 1912(d)) and the Washington Indian Child Welfare Act (RCW 13.38.130(1)); and (2) the termination petition did not provide the father with constitutionally sufficient notice of an alleged parenting deficiency that formed the basis for terminating his parental rights. See /n re Dependency of A.M.M., 182 Wn. App. 776, 791, 332 P.3d 500 (2014). The Department also acknowledges that it failed to offer services to address the alleged parenting deficiency as necessary to meet its burden under RCW 13.34.180(1)(d). We accept the Department's concessions. Accordingly, we reverse the order terminating the father’s parental rights and remand for further proceedings consistent with this opinion. No. 87372-5-1/2 Reversed and remanded. FOR THE COURT: bil, JZ
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