R.E.B. v. Dep't of Children & Families

Appellant appeals a final judgment terminating his parental rights arguing that his procedural due process rights were violated when the trial court held a manifest best interest hearing in his involuntary absence. We agree and reverse.1

The trial court held two adjudicatory hearings below. The first hearing, on November 2, 2017, considered only whether there were statutory grounds to terminate *958Appellant's parental rights. The trial court then held a second hearing, on November 9, 2017, addressing whether termination was in the children's manifest best interest and the least restrictive means…