best-interests analysis in Alaska

2022Servs., Off. of Child.’s Servs., 289 P.3d 924, 933 (Alaska 2012) (“We have repeatedly recognized that the best- interests analysis may include the child’s need for permanency at the time of the termination trial; and we have stated that ‘a child’s need for permanence and stability should not be put on hold indefinitely while the child’s parents seek to rectify the circumstances that cause their children to be in need of aid.’ ” (footnote omitted) (quoting Kent V., 233 P.3d at 603 )). 9 See Chloe W. v. State, Dep’t of Health &Soc.

2019Servs., Office of Children's Servs. , 289 P.3d 924 , 933 (Alaska 2012) ("We have repeatedly recognized that the best-interests analysis may include the child's need for permanency at the time of the termination trial.").

2019Houston v. Wolpert , 332 P.3d 1279 , 1282 (Alaska 2014) (quoting Borchgrevink v. Borchgrevink , 941 P.2d 132 , 134 (Alaska 1997) ).

2019That said, the superior court may need to reweigh the best-interests factors after it reconsiders factor five. 24 Houston v. Wolpert, 332 P.3d 1279, 1282 (Alaska 2014) (quoting (continued...) -11- 7337 Saffir asked the superior court to require Wheeler to be sober while with their daughter and to order affirmative measures to ensure his sobriety.

2022App. 2007) (“[A] court may apply the best-interests standard in a custody dispute between such parents without implicating the Fourteenth Amendment due-process rights of either parent.”). 13 592 P.2d 1233, 1241 (Alaska 1979) (“The establishment clause focuses judicial attention . . . in an effort to determine if the ‘religious’ is somehow being preferred over the non-religious, or anti-religious.”). 14 Id. at 1243 . 15 Id. at 1240-41 (stating that consideration of religiously motivated beliefs are appropriate when they impact the “actual religious needs” of the child, substantially threaten or

2022App. 2007) (“[A] court may apply the best-interests standard in a custody dispute between such parents without implicating the Fourteenth Amendment due-process rights of either parent.”). 13 592 P.2d 1233, 1241 (Alaska 1979) (“The establishment clause focuses judicial attention . . . in an effort to determine if the ‘religious’ is somehow being preferred over the non-religious, or anti-religious.”). 14 Id. at 1243 . 15 Id. at 1240-41 (stating that consideration of religiously motivated beliefs are appropriate when they impact the “actual religious needs” of the child, substantially threaten or

2022Servs., Off. of Child.’s Servs., 336 P.3d 1258, 1271 (Alaska 2014) (“The superior court may consider the bonding that has occurred between the child and his foster parents, the need for permanency, and the offending parent’s lack of progress.” (footnotes omitted)); Martin N. v. State, Dep’t of Health & Soc.

2018Servs., Office of Children’s Servs., 234 P.3d 1245, 1263 (Alaska 2010); see Thea G. v. State, Dep’t of Health & Soc.

2011Maxwell v. Maxwell, 37 P.3d 424, 426 (Alaska 2001) (concluding that superior court was not required to make best-interests determination where moving party failed to show substantial change in circumstances}. .

2005See State v. Phillips, 470 P.2d 266, 272 (Alaska 1970) (stating that "[t]he weight to be given to expert testimony is within the province of the trier of fact”). 14 .

1998See id. ) Because we conclude that he has not shown a substantial change, we need not decide whether to apply Turner , or the usual best-interests standard, in a parent-nonparent case in which a parent does surmount the substantial-change threshold. [8] See generally Adrienne E.