James H. v. Arizona Department of Economic Security

OPINION

SULT, Judge.

¶ 1 Appellant appeals the termination of his parental rights pursuant to Arizona Revised Statutes (“A.R.S.”) § 8-533(B)(4) (Supp.2003), the provision permitting severance based either on a felony conviction showing unfitness to parent or on a lengthy prison sentence. He argues that the Arizona Department of Economic Security failed to offer him family reunification services prior to seeking severance and therefore the severance should be overturned. Because we find that the Department has no duty to offer reunification services when the termination of parental rights is…