We review lower court factual findings only for clear error, and conclusions and applications of law de novo for correctness. In re L.N., 2014 MT 187, ¶ 12, 375 Mont. 480, 329 P.3d 598. A finding of fact is clearly erroneous only if not supported by substantial evidence or, upon our independent review, the record clearly manifests that the lower court misapprehended the effect of the evidence or was otherwise mistaken.
"A showing that the prior aggravated circumstances are relevant to the child at issue is not required." In re L.N ., 2014 MT 187, ¶ 23, 375 Mont. 480, 329 P.3d 598. Dismissal of the prior case involving D.D. does not render clearly erroneous the District Court's finding that Mother had subjected a child to chronic, severe neglect.
Section 41-3-422(1)(a), MCA, provides that an abuse and neglect petition may request certain relief including EPS, temporary investigative authority, TLC, termination of parental rights, or a determination that reunification services are not required. In re L.N. , 2014 MT 187, ¶ 15, 375 Mont. 480, 329 P.3d 598. Further, a petition may request any combination of relief "or any other relief that may be required for the best interest of the child."
We review a district court's factual findings to determine if they are clearly erroneous, and review conclusions of law de novo for correctness. In re L.N., 2014 MT 187, ¶ 12, 375 Mont. 480, 329 P.3d 598. A finding of fact is clearly erroneous if not supported by substantial evidence, if the trial court misapprehended the effect of the evidence, or if our review of the record convinces us that the court was mistaken.
¶ 9 We review a district court's decision to terminate parental rights for an abuse of discretion. In re L.N., 2014 MT 187, ¶ 12, 375 Mont. 480, 329 P.3d 598 (citation omitted). We review a district court's findings of fact for clear error and its conclusions of law for correctness.
¶16 We review a district court's decision to terminate parental rights for abuse of discretion. In re L.N., 2014 MT 187, ¶ 12, 375 Mont. 480, 329 P.3d 598. A district court abuses its discretion when it acts "arbitrarily, without employment of conscientious judgment or in excess of the bounds of reason, resulting in substantial injustice."
¶ 11 We review a district court's decision to terminate parental rights for abuse of discretion. In re L.N., 2014 MT 187, ¶ 12, 375 Mont. 480, 329 P.3d 598 (citations omitted). We review a district court's findings of fact for clear error and its conclusions of law for correctness. L.N., ¶ 12. An appellant bears the burden of establishing that the district court's factual findings are clearly erroneous.
¶ 18 “We review a district court's decision to terminate parental rights for abuse of discretion.” In re L.N., 2014 MT 187, ¶ 12, 375 Mont. 480, 329 P.3d 598 (citation omitted). We review a district court's findings of fact for clear error.
¶ 15 We review a district court's decision to terminate parental rights for abuse of discretion. In re L.N., 2014 MT 187, ¶ 12, 375 Mont. 480, 329 P.3d 598. We review the court's findings of fact for clear error and its conclusions of law for correctness. L.N., ¶ 12.
The District Court held a termination hearing in December 2014, and it entered a final order terminating Mother's parental rights to R.M.W. in January 2015. Mother appeals. ¶4 We review a district court's decision to terminate parental rights for an abuse of discretion. In re L.N., 2014 MT 187, ¶ 12, 375 Mont. 480, 329 P.3d 598. To terminate a parent's rights to a child under § 41-3-609(1)(f), MCA, a district court must determine by clear and convincing evidence that (1) a court has adjudicated the child a youth in need of care, (2) the parent has not complied with or been successful at an appropriate, court-approved treatment plan, and (3) the conduct or condition rendering the parent unfit is unlikely to change within a reasonable time.