Cloninger v. Russell

OPINION

This is an appeal from an order terminating the parental rights of appellant Cloninger to her natural son, Benjamin Russell. Proceedings were conducted in accordance with NRS 128.090(3) which provides that the standard of proof to be adduced in the proceedings is a preponderance of the evidence.

In Santosky v. Kramer, 455 U.S. 745, 102 S.Ct. 1388, 71 L.Ed.2d 599 (1982), which was decided after the hearing and order in this case, it was held by the United States Supreme Court that the due process clause of the fourteenth amendment of the United States Constitution requires, as a minimum,…