Introduction

The Minnesota Supreme Court resolved two recurring and consequential questions in termination of parental rights (TPR) practice: (1) whether, and when, a parent may move to withdraw an admission supporting a TPR judgment under Minnesota Rule of Juvenile Protection Procedure 56.03, subdivision 5(b); and (2) what process is required when such a motion is filed. The decision arises from Otter Tail County’s 2022 TPR petition against appellant father, D.A.A., who filed a written consent to voluntary termination and entered an admission at the admit/deny hearing. The district court terminated his rights in March 2023. Eighteen months later, he moved to withdraw his admission, alleging fraud, undue influence, and duress. The district court struck the motion, concluding he lacked standing because the TPR order was final. The court of appeals dismissed the ensuing appeal on similar grounds.

The Supreme Court reversed, holding that Rule 56.03, subdivision 5(b), unambiguously allows a motion to withdraw an admission “at any time” upon a showing that withdrawal is necessary to correct a manifest injustice, and that district courts must perform a threshold, prima facie assessment of the movant’s proffer. If that prima facie showing is made, the court must hold an evidentiary hearing; if not, the motion may be denied without one.

The ruling clarifies the interplay between procedural rules and statutory finality provisions in child-protection cases, reaffirms the judiciary’s primacy over procedural matters, and establishes a workable gatekeeping standard that seeks to protect both children’s interest in permanency and parents’ constitutional interest in fair TPR adjudications.

Summary of the Opinion

• Timeframe for Withdrawal: Minnesota Rule of Juvenile Protection Procedure 56.03, subd. 5(b) authorizes withdrawal of an admission “at any time” upon a showing that withdrawal is necessary to correct a manifest injustice. The phrase “at any time” means exactly that: there is no embedded time limit and no cross-application of the 10-day, 90-day, or 20-day limits that govern other forms of relief (posttrial motions, relief from a final order, or appeals).
• Procedural Gatekeeping: When such a motion is filed, the district court must first decide whether the motion and supporting materials make a prima facie showing that a manifest injustice occurred and that withdrawal is necessary to correct it. If so, the court must hold an evidentiary hearing. If not, the court may deny the motion without a hearing.
• Standing Misframed; Procedural Rules Control: The issue is not “standing” in the jurisdictional sense. Rather, it is a timing question governed by court rules. The court’s procedural rules control over contrary or competing statutory implications concerning participation after TPR finality.
• Outcome: Reversed and remanded to the district court to apply the prima facie standard to the motion and, if met, conduct an evidentiary hearing.

Analysis

A. Precedents and Authorities Cited

• Textual Canons and “Any” Means “All”
  • In re PERA Police & Fire Plan Line of Duty Disability Benefits of Brittain, 724 N.W.2d 512 (Minn. 2006): The use of “any” indicates inclusive breadth. Applied here to read “at any time” as unrestricted.
  • Hyatt v. Anoka Police Dep’t, 691 N.W.2d 824 (Minn. 2005); Olson v. Ford Motor Co., 558 N.W.2d 491 (Minn. 1997); Reynolds v. State, 888 N.W.2d 125 (Minn. 2016): Support giving “any” broad application and respecting “at any time” allowances (e.g., illegal sentences correctible “at any time”).
  • Canon against surplusage: The Court avoids interpretations that render words superfluous. Reading a 90-day limit into Rule 56.03, subd. 5(b) would erase “at any time.”
  • Expressio unius: Under Rules 21, 22, and 23, deadlines are expressly set (10/90/20 days), but none appears in Rule 56.03, subd. 5(b). The omission is intentional. See State v. Caldwell, 803 N.W.2d 373 (Minn. 2011).
• Procedural Primacy and Separation of Powers
  • In re Welfare of J.R., Jr., 655 N.W.2d 1 (Minn. 2003); Wells Fargo Bank, N.A. v. True Gravity Ventures, LLC, 23 N.W.3d 837 (Minn. 2025): The judiciary has primary responsibility for trial and appellate procedure; the rules govern procedural timing.
  • In re Welfare of Child of R.K., 901 N.W.2d 156 (Minn. 2017): Rule interpretation is de novo and guided by text and purpose.
• Best Interests, Finality, and the Parent-Child Relationship
  • In re Welfare of M.D.O., 462 N.W.2d 370 (Minn. 1995): Best interests are paramount in child-protection cases.
  • In re Welfare of Children of G.A.H., 998 N.W.2d 222 (Minn. 2023): Recognizes the parent’s “commanding” constitutional interest in accurate and just TPR decisions.
  • In re Welfare of J.R., Jr., 655 N.W.2d at 5: Courts must avoid allowing children to “linger in uncertainty.”
• Manifest Injustice and Coercion—TPR and Criminal Plea Contexts
  • State v. Theis, 742 N.W.2d 643 (Minn. 2007); State v. Wolske, 160 N.W.2d 146 (Minn. 1968): In criminal cases, manifest injustice supports withdrawal when pleas are invalid, including where coercion or official deceit is shown.
  • State v. Kaiser, 469 N.W.2d 316 (Minn. 1991): Evidentiary hearing required on claim of plea coercion in criminal context. The Court distinguishes that approach here due to children’s strong interest in permanency.
  • In re Welfare of Child. of M.L.A., 730 N.W.2d 54 (Minn. App. 2007): Court of Appeals required an evidentiary hearing for TPR admission-withdrawal claims alleging coercion when filed within 90 days. The Supreme Court narrows that rule: no automatic hearing; a prima facie showing is required.
• Prima Facie and Hearing Standards from Family Law
  • Goldman v. Greenwood, 748 N.W.2d 279 (Minn. 2008); Morey v. Peppin, 375 N.W.2d 19 (Minn. 1985); Silbaugh v. Silbaugh, 543 N.W.2d 639 (Minn. 1996): In family law, evidentiary hearings are required only when affidavits make a prima facie case for relief; conclusory allegations are insufficient.
  • State v. LeDoux, 770 N.W.2d 504 (Minn. 2009); Mathews v. Eldridge, 424 U.S. 319 (1976): Due process does not always require full evidentiary hearings.
  • DeCook v. Olmsted Med. Ctr., Inc., 875 N.W.2d 263, 276 n.5 (Minn. 2016) (Dietzen, J., concurring/dissenting): Conclusory assertions do not make out a prima facie case.
• “Standing” Misframed
  • In re Custody of D.T.R., 796 N.W.2d 509 (Minn. 2011): Standing is the right to bring a claim; here, the Court reframes the issue as procedural timing, not subject-matter standing, and recognizes parents are parties to TPR proceedings. See also Minn. Stat. § 260C.307, subd. 3; Minn. R. Juv. Prot. P. 32.01, subd. 3(a).

B. The Court’s Legal Reasoning

1. Plain Meaning of Rule 56.03, subd. 5(b): The operative text—“An admission may be withdrawn … at any time, upon a showing that withdrawal is necessary to correct a manifest injustice”—is unambiguous. “At any time” is inclusive and unconditional. No external time limit (10/90/20 days) is grafted onto it from other rules (21, 22, or 23), because doing so would violate canons against surplusage and the expressio unius principle.
2. Procedural vs. Substantive Framing—Rules Control: The State’s “standing” rationale under Minn. Stat. § 260C.317, subd. 1 (limiting participation post-termination) mischaracterized the problem. The question is procedural timing, governed by the court’s rules. Under separation of powers, court-promulgated procedures prevail in matters of timing and process. The Court therefore treats Rule 56.03’s unqualified timing language as dispositive.
3. Child’s Best Interests and Permanency Remain Central: The Court reconciles the lack of a time limit with the child’s strong interest in finality by emphasizing the narrowness of the “manifest injustice” standard. Most admissions will remain undisturbed; only rare, extraordinary injustices justify reopening.
4. No Automatic Evidentiary Hearing; Prima Facie Gatekeeping: Borrowing the well-developed framework from custody-modification jurisprudence, the Court holds that an evidentiary hearing is required only if the motion and supporting materials—taken as true—make a prima facie showing of manifest injustice and the necessity of withdrawal to correct it. Bare assertions or conclusory claims do not suffice. This approach balances due process with the need to avoid unnecessary delays that harm children’s stability.

C. Practical Impact

• Clear, new statewide rule of procedure:
  • Timing: Parents who entered admissions to TPR petitions may seek withdrawal “at any time.” This is a new, definitive statement that rejects implied time bars once TPR judgments are final.
  • Process: District courts must perform a threshold, prima facie review based on affidavits and documentary proffers. Only if that threshold is met must the court hold an evidentiary hearing.
• Heightened pleading and evidentiary expectations for movants: Motions must be supported by specific, non-conclusory facts and evidence (e.g., detailed affidavits, contemporaneous communications, medical or psychological records, transcripts indicating defective colloquy, proof of misrepresentation or coercion) establishing both manifest injustice and the necessity of withdrawal to correct it.
• County and guardian ad litem responses: Expect more targeted, affidavit-based opposition at the threshold stage. Counties should preserve and present record materials that demonstrate voluntariness, robust advisements at the admit/deny hearing, and the child’s current permanency status to help the court assess whether any alleged injustice would meet the demanding standard.
• Bench-level triage and written findings: District courts should issue short, reasoned orders that:
  • Identify the alleged injustice and the evidentiary support;
  • Decide whether the proffer meets the prima facie threshold;
  • Set an evidentiary hearing if the threshold is met, with defined scope on the manifest injustice issues.
• Colloquy and record-building going forward: To prevent later disputes, courts and counsel should ensure a comprehensive on-the-record colloquy addressing voluntariness, absence of threats or promises, mental-health status, understanding of finality, and the child’s best interests. Written consents should be clear, detailed, and signed under oath; interpreters and other accommodations should be documented.
• Rulemaking horizon: The Court notes that policy calibration—e.g., whether to add a time limit—belongs in rulemaking, not adjudication. Practitioners should monitor potential amendments to Rule 56.03, subd. 5(b).
• Adoption and permanency implications: The opinion does not address how a successful withdrawal interacts with a finalized adoption or other permanency outcomes. Those questions remain for future cases and/or rulemaking and will likely be resolved with the child’s best interests and statutory protections for finalized adoptions at the forefront.

Complex Concepts Simplified

• Admission to a TPR petition vs. consent to termination:
  • An “admission” is the parent’s on-the-record acknowledgment of the petition’s allegations or grounds, typically at an admit/deny hearing, that provides a factual basis for termination.
  • “Consent” to termination (e.g., under Minn. Stat. § 260C.301, subd. 1(a)) is a written, voluntary relinquishment. In practice, these often accompany each other and together support the TPR order.
• Manifest injustice: A high standard reserved for clear, fundamental unfairness undermining the integrity or voluntariness of the admission. Examples may include:
  • Coercion, duress, or undue influence (e.g., threats, grossly unfair pressure);
  • Material misrepresentation by officials inducing the admission;
  • Invalid colloquy—e.g., the parent did not understand the rights waived or the consequences, due to lack of adequate advisement, language issues, or cognitive barriers;
  • Other rare circumstances showing the admission was not truly voluntary or accurate.
  Not every regret or later change of heart qualifies.
• Prima facie showing: A threshold showing that, if the movant’s factual proffer is accepted as true, it would establish manifest injustice and the need for withdrawal to correct it. Conclusory allegations are insufficient; specific facts with supporting evidence are required.
• Evidentiary hearing: A live hearing with testimony and exhibits. After this decision, such a hearing is not automatic; it is triggered only when the prima facie threshold is met.
• Standing vs. timing: “Standing” refers to the right to bring a claim in court. The Court explains that the right to file a Rule 56.03 motion is not about standing but timing—i.e., when the rules allow a party (even post-TPR) to seek relief from an admission. Rule 56.03 explicitly permits it “at any time.”
• Procedural rule supremacy: In Minnesota, the Supreme Court’s rules govern court procedure. If a statute appears to conflict on procedural timing, the court rules control.

Practice Pointers and Checklists

For movants (parents and counsel)

• File a detailed affidavit explaining:
  • Specific facts showing coercion, duress, misrepresentation, or other injustice;
  • When and how the injustice occurred (names, dates, places, documents);
  • Why withdrawal is necessary to correct the injustice (e.g., no lesser remedy suffices);
  • Supporting exhibits (texts/emails, recordings, medical reports, interpreter records, hearing transcripts showing deficiencies).
• Address the child’s current situation to explain how the requested relief will be managed in light of best interests and permanency planning.
• Avoid conclusory assertions; provide corroboration wherever possible.

For county attorneys/guardians ad litem

• Respond at the threshold stage with affidavits attaching the admit/deny transcript, written consent, colloquy details, and any communications refuting coercion.
• Document the child’s permanency posture (placement/adoption status) to inform the court’s materiality analysis.
• Propose targeted issues and witnesses if an evidentiary hearing is ordered.

For district courts

• First, decide whether the motion makes a prima facie showing. If yes, set an evidentiary hearing and define its scope; if no, deny without a hearing.
• Issue short, clear orders explaining the prima facie determination, referencing specific factual proffers and evidence.
• At any evidentiary hearing, make explicit findings on voluntariness, credibility, and whether any injustice requires withdrawal.

For everyone—record-building at the initial admission

• Conduct a comprehensive colloquy:
  • Voluntariness and absence of threats/promises;
  • Understanding of rights waived and finality;
  • Interpreters or accommodations used;
  • Best-interests understanding;
  • Opportunity to consult counsel and adequate time to consider.
• Confirm the written consent aligns with the on-the-record colloquy.

Unresolved or Reserved Issues

• Standard of proof at the evidentiary hearing: The Court specifies the prima facie threshold for getting a hearing but does not expressly define the burden of proof or precise evidentiary standard at the hearing stage.
• Interplay with finalized adoptions: The opinion does not address whether, or how, relief would operate if an adoption has since been finalized, an area typically governed by separate statutory protections and best-interests analyses.
• Ineffective assistance of appellate counsel: The Court declined to reach whether such a claim can be raised via a motion to reinstate a direct appeal after finality (n.1).
• Future rulemaking: The Court flags the possibility that the rule’s unlimited timeframe might be rebalanced in the rulemaking process (n.3).

Conclusion

This decision squarely answers two long-standing questions in Minnesota juvenile protection practice. First, a parent who entered an admission supporting TPR may move to withdraw that admission “at any time” under Rule 56.03, subd. 5(b)—even long after the TPR order has become final—so long as the motion seeks to correct a manifest injustice. Second, district courts must serve as gatekeepers: an evidentiary hearing is not automatic. The court must determine whether the motion and supporting materials establish a prima facie case of manifest injustice and the necessity of withdrawal; only then must a hearing be held.

The ruling fortifies the judiciary’s control over procedural matters, respects the primacy of the child’s best interests by narrowing evidentiary hearings to cases with substantial preliminary showings, and safeguards parents’ fundamental rights by preserving a pathway to correct extraordinary injustices. It also incentivizes rigorous, clearly documented admissions and colloquies at the front end of TPR proceedings, which should, in turn, reduce the incidence of meritorious post-judgment challenges.