But mother's admission to the facts in the petition to transfer custody and her "consent to the transfer did not automatically change the transfer from involuntary to voluntary." In re Child of A.S., 698 N.W.2d 190, 195 (Minn.App. 2005), review denied (Minn. Sept. 20, 2005).
An appellate court reviews an order terminating parental rights to determine whether the district court's findings address the statutory criteria, are supported by substantial evidence, and are not clearly erroneous. In re Child of A.S., 698 N.W.2d 190, 194 (Minn.App. 2005), review denied (Minn. Sept. 20, 2005).
We review whether the court's findings are supported by substantial evidence. In re Child of A.S., 698 N.W.2d 190, 194 (Minn.App. 2005), review denied (Minn. Sept. 20, 2005).
On appeal, we review termination-of-parental-rights orders to ascertain whether the district court's findings address the statutory criteria, are supported by substantial evidence, and are not clearly erroneous. In re Child of A.S., 698 N.W.2d 190, 194 (Minn.App. 2005), review denied (Minn. Sept. 20, 2005).
"The statute does not require that the parent has inflicted egregious harm on his own child, but rather, that a child has experienced egregious harm in the parent's care, which demonstrates the parent's grossly inadequate ability to provide minimally adequate parental care to any child." In re Child of A.S., 698 N.W.2d 190, 197 (Minn. App. 2005), review denied (Minn. Sept. 20, 2005).
The parent need not have egregiously harmed the child in question; rather, the county's petition may rely on "any child" in the parent's care. In re Child of A.S., 698 N.W.2d 190, 197 (Minn. App. 2005), review denied (Minn. Sept. 20, 2005).
While there is no statutory definition of "good cause" for purposes of a voluntary termination of parental rights, a factual basis for good cause "center[s] on the child’s best interests." In re Welfare of Child of J.K.T. , 814 N.W.2d 76, 86 (Minn. App. 2012) ; see In re Child of A.S. , 698 N.W.2d 190, 195 (Minn. App. 2005) (noting that "good cause for voluntary termination [of parental rights] exists under a variety of circumstances usually related to the best interests of the child"), review denied (Minn. Sept. 20, 2005).
"The statute does not require that the parent has inflicted egregious harm on his own child, but rather, that a child has experienced egregious harm in the parent's care." In re Child of A.S., 698 N.W.2d 190, 197-98 (Minn. App. 2005), review denied (Minn. Sept. 20, 2005).
"We defer to the district court's findings, but exercise great caution in proceedings to terminate parental rights and examine the evidence to determine whether it is clear and convincing." In re Welfare of Child of A.S., 698 N.W.2d 190, 194 (Minn. App. 2005) (quotation omitted), review denied (Minn. Sept. 20, 2005).
And we conclude that the word "parent" refers to the person who is the subject of the termination proceedings; it does not imply a special kind of care or that this person is the parent of the child who was egregiously harmed. See, e.g. , In re Child of A.S. , 698 N.W.2d 190, 197 (Minn. App. 2005) ("The statute does not require that the parent has inflicted egregious harm on his own child, but rather, that a child has experienced egregious harm in the parent’s care ...." (emphasis added)), review denied (Minn. Sept. 20, 2005).