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Case Law Update

Court Can Only Enter Default Judgment in Termination of Parental Rights Proceeding After Agency Meets Statutory Requirements

Unlike civil cases in which no proof is required before a judgment by default can be entered against a nondefending or appearing party, the juvenile court can only enter a default judgment in a termination of parental rights proceeding when the child welfare agency establishes the required statutory grounds for termination by clear and convincing evidence, regardless of whether the parent appears.