C.L. v. Florida Department of Children & Families

We conclude that the trial court erred in holding the final hearing on termination of parental rights at a time when the appellant could not be present. Although the appellant was aware that his failure to appear at the hearing would be deemed a consent to termination, he had informed the court prior to the hearing that he could not attend on the scheduled date because he was working in Louisiana and could neither miss work nor afford to make the trip until he was paid. See In re H.S., 995 So.2d 516, 516 (Fla. 2d DCA 2008) (deeming financial hardship of a parent a circumstance beyond the…