Department of Human Services v. J. M.

Mother and father appeal a permanency judgment that changed the permanency plan for their child, L, from reunification to adoption. On appeal, parents first contend that the juvenile court violated their due process rights by admitting into evidence out-of-court statements contained within three reports without providing parents the opportunity to cross-examine the authors of those reports. Parents also challenge the court’s determination that DHS made active efforts to reunify the family1 and that, despite those efforts, parents had not made sufficient progress to allow L to be safely…