Procedural Compliance and Best-Interest Emphasis in Termination of Parental Rights

Introduction

In In the Matter of the Termination of Parental Rights to SLD, a Minor Child; Katrina Danforth v. Ryan Hansen (2025 WY 39), the Supreme Court of Wyoming addressed the procedural and substantive standards governing the termination of parental rights. Appellant Katrina Danforth, proceeding pro se, appealed from the Sheridan County District Court’s post-remand order dismissing her counterclaim against Appellee Ryan Hansen. The dispute concerns: (1) the adequacy of the Department of Family Services’ social study; (2) the district court’s refusal to appoint a guardian ad litem for the child; (3) the dismissal of Danforth’s counterclaim without a separate evidentiary hearing; and (4) whether termination of parental rights impermissibly extended Danforth’s punishment for a federal felony conviction.

Summary of the Judgment

Justice Boomgaarden, writing for a unanimous Court, affirmed the district court. Key holdings:

1. The social study prepared under Wyo. Stat. § 14-2-314 was properly admitted and posed no prejudice because Danforth testified extensively at trial.
2. Under Wyo. Stat. § 14-2-312, the court complied with its choice to make on-the-record findings that a guardian ad litem was unnecessary.
3. Danforth forfeited any right to a separate hearing on her counterclaim by failing to develop or prosecute it at trial.
4. Termination of parental rights under Wyo. Stat. § 14-2-309(a)(iv) is not a punitive extension of Danforth’s criminal sentence but rather a decision grounded in the child’s best interests and statutory criteria.

Analysis

Precedents Cited

• SLD I (2024 WY 50): The Court dismissed Danforth’s first appeal for lack of jurisdiction because the district court had not resolved her counterclaim.
• In re WDW, 2010 WY 9: Held that absence of a parent’s personal interview in a social study was not reversible when the parent testified at trial.
• In re MN, 2007 WY 189: Emphasized the court’s dual obligation under § 14-2-312—to appoint a guardian ad litem or to make express findings when one is unnecessary.
• MB v. Laramie County Dep’t of Family Servs., 933 P.2d 1126 (Wyo. 1997): Stressed strict compliance with the Termination of Parental Rights Act.
• Matter of BAD, 2019 WY 83: Recognized parental rights as fundamental but subject to termination when statutory grounds are met and a child’s best interest demands it.
• Interest of RAA, 2016 WY 117 & NRAE, 2020 WY 121: Clarified the two-step analysis—proof of statutory grounds by clear and convincing evidence, then consideration of the child’s best interests.

Legal Reasoning

The Court’s reasoning unfolded in four parts:

1. Social Study (§ 14-2-314)
   The statute mandates a social study “to aid the court.” Although Danforth did not appear in the study, she testified fully about her background, prison programs, and parenting history. Under In re WDW, hearsay in such a report is admissible and non-prejudicial if the parent’s own testimony supplements the record.
2. Guardian ad Litem (GAL) Appointment (§ 14-2-312)
   The Court has two choices: appoint a GAL or record findings that one is unnecessary. Despite Danforth’s request, she never moved formally or objected when the court announced its finding. Her silence amounted to forfeiture, and the court’s on-record determination that Hansen adequately represented the child complied with In re MN.
3. Counterclaim Dismissal
   Under W.R.C.P. 42, separate trials are discretionary. Danforth did not request one, did not introduce evidence to support her allegations, and omitted the counterclaim from both her Pre-trial Memorandum and post-trial filings. The rule against sandbagging forecloses reversal where a party fails to prosecute a claim at trial (Willmschen v. Meeker).
4. Punitive vs. Best-Interest Analysis
   While a parent’s felony conviction can establish statutory grounds under § 14-2-309(a)(iv), termination turns on present parental capacity and the child’s best interest. The Court rejected the notion that the TPR proceeding functioned as an extension of Danforth’s federal sentence, echoing Matter of BAD and emphasizing the primacy of a stable home environment for SLD.

Impact

This decision reinforces several enduring principles in Wyoming child-welfare law:

• Strict adherence to statutory procedures (social studies, GAL appointment, proof standards) remains non-waivable.
• Parties must timely assert and develop all claims and counterclaims or risk forfeiture.
• Termination proceedings focus not on punishment but on the child’s welfare—underscoring that criminal history, while relevant, is not dispositive absent best-interest findings.

Lower courts will rely on Danforth v. Hansen when assessing whether to appoint a guardian ad litem, determining the need for additional social studies, and gauging the sufficiency of proof for counterclaims in TPR actions.

Complex Concepts Simplified

Social Study

A written report by child-welfare professionals summarizing the child’s and family’s circumstances. Admissible even if based on hearsay, so long as the parent has an opportunity to testify.

Guardian ad Litem (GAL)

An independent attorney appointed to represent the child’s best interests. Under Wyoming law, a court need not appoint one if another party already advocates adequately without adverse interests.

Clear and Convincing Evidence

A mid-level burden of proof requiring that the truth of the facts is highly probable—higher than “preponderance” but lower than “beyond a reasonable doubt.”

Waiver vs. Forfeiture

Waiver: Intentional relinquishment of a known right (no review).
Forfeiture: Failure to assert a right timely (reviewable only for plain error).

Best-Interest Standard

After statutory grounds are established, the court must decide whether terminating parental rights serves the child’s physical, emotional, and developmental needs.

Conclusion

Danforth v. Hansen clarifies that procedural safeguards in TPR proceedings—social studies, GAL appointments, and the opportunity for evidentiary hearings—are mandatory but subject to waiver or forfeiture if not properly invoked. The decision also reinforces that termination of parental rights is not a vehicle for additional criminal punishment but a measure focused on the child’s best interests once statutory grounds are met. Going forward, this opinion will guide courts and practitioners in ensuring both procedural compliance and principled, child-centered adjudications in parental-rights cases.