State ex rel. Human Services Department v. Wayne R.N.

OPINION

MINZNER, Judge.

Respondents appeal from the judgment of the trial court terminating their parental rights. Although in other contexts New Mexico law requires that grounds for termination be proved by clear and convincing evidence, In re Adoption of Doe, 98 N.M. 340, 648 P.2d 798 (Gt.App.1981), in termination proceedings involving parental rights to a child subject to the Indian Child Welfare Act, the grounds for termination must be proved by evidence beyond a reasonable doubt. See NMSA 1978, § 32-l-54(D) (Repl.1986) and 25 U.S.C. § 1912(f) (1982). On appeal, respondents contend (1) that…