IN RE THE MATTER OF: A.J.S., a child under seventeen years of age, by J.L.S., Petitioner-Respondent v. C.R.

J.L.S. (“Father”), the biological father of A.J.S. (“Child”), brought this “private action” under section 211.447, 1 to terminate the parental rights of C.R.- (“Mother”), the biological mother of Child. Mother raised the affirmative defense that the petition failed to state a claim because there was non-compliance with section 211.447, and also complained that the termination of parental rights is a creature of statute, requiring strict and literal compliance with the statutory authority. Mother brings these same complaints in her points in this appeal. We will discuss all three points…