Where inadmissible evidence admitted at trial is cumulative only and other admissible evidence supports the result, the cumulative evidence, though inadmissible, is nonprejudicial. Matter of N.J.W., 273 N.W.2d 134, 138 (S.D. 1978); Matter of D.T., 89 S.D. 590, 599, 237 N.W.2d 166, 171 (1975); Alberts v. Mutual Service Casualty Insurance Co., 80 S.D. 303, 315, 123 N.W.2d 96, 103 (1963). [ΒΆ 15.] A review of the letter evidence indicates it was cumulative.
See also In Re Hanks, 553 A.2d 1171, 1175-76 (Del. 1989) (parent fails to "plan adequately" for child's needs); Matter of Gentry, 369 N.W.2d 889, 893 (Mich. App. 1985) ("fit home," "proper home," "proper care and custody," and "mental deficiency or mental illness"); Chandler v. Cochran, 275 S.E.2d 23, 26-27 (Ga.) (parent fails to "provide for the care and support of the child"), cert. denied, 454 U.S. 872, reh'g denied 454 U.S. 1094 (1981); In Re Metteer, 279 N.W.2d 374, 377-78 (Neb. 1979) ("parental responsibilities"); State ex rel. Health Social Servs. Dep't v. Natural Father, 598 P.2d 1182, 1185 (N.M. 1979) ("other care or control" and "incapacity"); In Matter of D.T., 237 N.W.2d 166, 169 (S.D. 1975) ("lacks proper parental care" and "whose environment is injurious to his welfare"); In the Interest of J.Z., 190 N.W.2d 27, 35-36 (N.D. 1971) (a deprived child is one "without proper parental care or control").