In re the Welfare of S.I.

¶1 A party who fails to appear in an action is not entitled to notice prior to entry of a default order. We are asked to decide whether a mother who appeared and participated in a dependency action yet failed to appear in a subsequent termination proceeding is required to receive notice prior to entry of a default order in the termination proceeding. We hold that a dependency proceeding is separate from a termination proceeding. We also hold that a parent’s appearance and participation in a dependency proceeding does not constitute an appearance in a later termination proceeding. Therefore, a…