In the Interest Of: RAA, AMA, and CMA, Minor Children, RA v. AW

DAVIS, Justice.

[¶1] RA (Father) appeals a district court decision terminating his parental rights. He argues that the statutory requirements for termination in Wyo. Stat. Ann. § 14—2— 309(a)(i) (LexisNexis 2015) were not met. We agree with Father that communications he directed to his children were not merely incidental. As a result, the requirement that there be no communication from the absent parent for a period of at least one year was not proven by clear and convincing evidence. We must therefore reverse.

ISSUE

[¶2] While Father presents a number of issues, we find the following narrow…