Dougherty v. State (In re J.L.O.)

DARBY, J.:

¶ 1 The questions presented to this Court are whether 1) the district court abused its discretion by denying Mother's motion to continue and allowing her waiver of jury trial; 2) a witness testifying telephonically violated Mother's right to procedural due process; 3) the State presented clear and convincing evidence to support the termination of parental rights; and 4) Mother's trial counsel provided effective assistance. We answer the first two questions in the negative and the last two in the affirmative.

I. BACKGROUND AND PROCEDURAL HISTORY

¶ 2 Mother gave birth to Child on June…