J.E. v. V.C.E.

Although the district court erred in finding that the father had voluntarily relinquished his parental rights, the district court is not precluded on remand from finding abandonment on some other basis if clear and convincing evidence supporting such a finding exists. I write specially to address the district court’s error, under our current jurisprudence, in failing to consider whether viable alternatives to terminating the father’s parental rights exist that would be in the child’s best interests, even upon a finding of abandonment.

The father argues that the district court erred by not…