State Health & Social Services Department v. Smith

OPINION

WOOD, Chief Judge.

This appeal involves the termination of the parental right of the mother of a child, approximately 2Vz years old at the termination hearing. The mother’s appeal raises issues as to the trial court’s findings, which need not be discussed, either because the particular finding is supported by substantial evidence or because irrelevant to the decision. We discuss: (1) Evidence Rule 504, the psychotherapist-patient privilege, and (2) requirements for termination of the mother’s parental right.

The child, whose father is unknown, was born October 15, 1975; the child had…