Jenkins v. Department of Social & Health Services

¶1 The legislature has provided that before a trial court terminates a parent-child relationship, the *572court must find, among other things, that the child has been found to be a dependent child. In this case, the order finding the child K.N.J. dependent as to her father, petitioner Michael Jenkins, was void because the order was entered by a pro tempore judge without Jenkins’ consent. Nonetheless, we hold that K.N.J.’s dependency was amply proved at the termination trial, where Jenkins was present and represented by counsel, and supported by findings of fact made by a constitutionally valid…