P.E. v. Department of Children & Family Services

DAVIS, Judge.

P.E. (“the Mother”) challenges the trial court’s termination of her parental rights to her child, H.E., which was based on the Mother’s failure to appear at the final adjudicatory hearing. We reverse and remand.

On appeal, the Mother argues that the trial court erred by failing to require the Department to prove the basis for the termination. The Mother maintains that pursuant to S.S. v. Department of Children & Family Services, 976 So.2d 41 (Fla. 3d DCA 2008), after the trial court found that she consented to the TPR by her failure to appear, it was still required to take…