Indigent parents are entitled to a record at state expense complete enough to allow fair appellate consideration of parents' claims. M.L.B., 519 U.S. at 128, 117 S.Ct. 555; In re Austin C., No. M2013–02147–COA–R3–PT, 2014 WL 4261178, at *6 (Tenn.Ct.App., Aug. 27, 2014). Indigent parents are provided appointed counsel on appeal.
Indigent parents are entitled to a record at state expense complete enough to allow fair appellate consideration of parents' claims. M.L.B., 519 U.S. at 128, 117 S.Ct. 555; In re Austin C., No. M2013–02147–COA–R3–PT, 2014 WL 4261178, at *6 (Tenn.Ct.App., Aug. 27, 2014). Indigent parents are provided appointed counsel on appeal.
If the trial court has determined that the parent is indigent, the court must "ensure there is a record of trial evidence that is sufficiently complete to allow an appellate court to review the evidence in accordance with applicable standards, even when the petition to terminate parental rights is filed by a private party." In re Austin C., No. M2013-02147-COA-R3-PT, 2014 WL 4261178, at *4 (Tenn. Ct. App. Aug. 27, 2014) (citing In re Adoption of J.D.W., 2000 WL 1156628, at *4 n.5); see also M.L.B. v. S.L.J., 519 U.S. 102, 116 n.8 (1996) (explaining that state action is invoked when a private party asks the state to terminate a parental relationship).
Id. In re Austin C. , No. M2013-02147-COA-R3-PT, 2014 WL 4261178, at *4-5 (Tenn. Ct. App. Aug. 27, 2014) (emphasis added). In the case at bar, we have not been presented with a record of sufficient completeness so as to permit proper appellate review of the statutory grounds for termination of parental rights or the best interest analysis.
A record of sufficient completeness is required to permit proper appellate review of a parent's claims in termination of parental rights proceedings. See In re Ian B., M2015-01079-COA-R3-PT, 2016 WL 2865875 (Tenn. Ct. App. May 11, 2016); In re Austin C., No. M2013-02147-COA-R3-PT, 2014 WL 4261178 (Tenn. Ct. App. Aug. 27, 2014); L.D.N. v. R.B.W., No.E2005-02057-COA-R3-PT, 2006 WL 369275 (Tenn. Ct. App. Feb. 17, 2006); In re J.M.C.H., No. M2002-01097-COA-R3-JV, 2002 WL 31662347 (Tenn. Ct. App. Nov. 26, 2002); In re Adoption of J.D.W., No. M2000-00151-COA-R3-CV, 2000 WL 1156628 (Tenn. Ct. App. Aug. 16, 2000). While we always prefer having a transcript of the underlying proceeding, it is not specifically required; instead, a "record of sufficient completeness" is required.
See, e.g., In re Austin C., No. M2013-02147-COA-R3-PT, 2014 WL 4261178 at *6 (Tenn. Ct. App. Aug. 27, 2014) (affirming the termination of the mother's parental rights following review of an evidentiary record comprised in part of a statement of the evidence). It is well settled that "in cases involving the termination of parental rights, a record of the proceeding of sufficient completeness to permit proper appellate consideration of the parent's claims must be made in order to preserve that parent's right to an effective appeal."