In re Jane Doe 16-A

Affirmance is due whether under the more deferential standard of appellate review established by the Legislature in 2011, see § 390.01114(4)(b)(2), Florida Statutes, or the more pliant one previously fashioned and applied by Florida appellate courts. See generally In re Doe 13-A, 136 So.3d 723 (Fla. 1st DCA 2014) (concurring/dissenting opinions discussing the different standards).1 The minor’s testimony, which was not subject to cross-examination, fell short of the clear and convincing standard required to obtain a judicial order that her parents not be notified she is seeking to terminate…