I.R. v. Department of Children & Family Services

VILLANTI, Judge.

I.R., the Mother, appeals the termination of her parental rights to her son, R.R. As the Department properly concedes, because we have reversed the termination of the Father’s parental rights, see W.P.R. v. Dep’t of Children & Family Servs., 17 So.3d 851 (Fla. 2d DCA 2009), and because the Department did not establish grounds for a single parent termination, we must reverse the termination order as to the Mother as well.

Unique problems arise when both parents’ parental rights are terminated in a single proceeding and the appellate court subsequently determines that the…