District courts must explain their rationale in a best-interests analysis. In re Tanghe, 672 N.W.2d 623, 626 (Minn. App. 2003). "Determination of a child's best interests is 'generally not susceptible to an appellate court's global review of a record,' because of the credibility determinations involved, and because of the multiple factors that must be weighed."
And the court neither addressed nor made any findings from the bench concerning good cause to accept J.L.L.'s consent to voluntarily terminate her parental rights or the best interests of K.L.L. See In re Tanghe, 672 N.W.2d 623, 625-26 (Minn.App. 2003) (holding that in termination proceedings, district court must consider child's best interests and explain rationale in findings and conclusions and that failure to do so is error requiring remand). The record shows that before the court received J.L.L.'s written revocation of consent, it did not issue an order terminating J.L.L.'s parental rights to K.L.L.
In a TPR proceeding, the district court must consider the child's best interests and explain why termination is in the best interests of the child. In re Tanghe, 672 N.W.2d 623, 626 (Minn.App. 2003). Appellant-parents claim that the district court's failure to make findings regarding S.M.H.'s best interests is an error that requires remand.
1978) (citing Minn. R. Civ. P. 52.01). Appellate review "takes into account the substantive evidentiary burden of clear and convincing evidence." In re Tanghe, 672 N.W.2d 623, 625 (Minn.App. 2003) (citing In re Welfare of Clausen, 289 N.W.2d 153, 156 (Minn. 1980)).
"Determination of a child's `best interests,' . . . is generally not susceptible to an appellate court's global review of a record[ ]" because "an appellate court's combing through the record to determine best interests is inappropriate because it involves credibility determinations." In re Tanghe, 672 N.W.2d 623, 625 (Minn.App. 2003). In its order terminating father's parental rights, the district court stated in its findings that "[t]ermination of the parents' parental rights is in the best interests of the child.
When an appellate court reviews the best-interests determination, it should not comb through the record to determine the children's best interests because it involves credibility determinations. In re Tanghe, 672 N.W.2d 623, 625 (Minn. App. 2003) (citing Schmidt v. Schmidt, 436 N.W.2d 99, 105 (Minn. 1989)); see also In re Welfare of Child of D.L.D., 771 N.W.2d 538, 546 (Minn. App. 2009).
Instead, the district court "must consider a child's best interests and explain its rationale in its findings and conclusions." In re Tanghe, 672 N.W.2d 623, 626 (Minn. App. 2003). Here, the district court made a conclusory statement that "[i]t is in the best interests of [the child] that the parental rights of Mother be involuntarily terminated."
The district court's order terminating parental rights must explain its "rationale for concluding why the termination is in the best interests of the child[]." In re Tanghe, 672 N.W.2d 623, 625 (Minn. App. 2003). "[D]etermination of a child's best interests 'is generally not susceptible to an appellate court's global review of a record,' and . . . 'an appellate court's combing through the record to determine best interests is inappropriate because it involves credibility determinations.'"
The district court's order terminating parental rights must explain its "rationale for concluding why the termination is in the best interests of the child[]." In re Tanghe, 672 N.W.2d 623, 625 (Minn. App. 2003). "[D]etermination of a child's best interests 'is generally not susceptible to an appellate court's global review of a record,' and . . . 'an appellate court's combing through the record to determine best interests is inappropriate because it involves credibility determinations.'"
The district court "must consider a child's best interests and explain its rationale in its findings and conclusions." In re Tanghe, 672 N.W.2d 623, 626 (Minn. App. 2003). "[C]onflicts between the rights of the child and rights of the parents are resolved in favor of the child."