parent challenge (New Mexico) · Go Syfert
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parent challenge in New Mexico

8 New Mexico opinions name it 2 courts 2007–2020 0 in the last five years

The cases below were cited by New Mexico courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
In re Christina M.green
conn · 2006 · cited in 2 New Mexico opinions naming this issue, 2009–2009
2 sentences

2009See In re Christina M., 280 Conn. 474 , 908 A.2d 1073, 1080 (2006) (recognizing that the inadequate representation of a child in a TPR case could affect the outcome, and thus a parent has a claim of injury sufficient to confer standing).

2009See In re Christina M., 280 Conn. 474 , 908 A.2d 1073, 1080 (2006) (recognizing that the inadequate representation of a child in a TPR case could affect the outcome, and thus a parent has a claim of injury sufficient to confer standing).

22
State ex rel. Children, Youth & Families Departmentgreen
nmctapp · 2002 · cited in 1 New Mexico opinions naming this issue, 2020–2020
1 sentence

2020Children, Youth & Families Dep’t v. Tammy S., 1999-NMCA-009, ¶ 15 , 126 N.M. 664 , 974 P.2d 158 (holding that the “[f]ather’s transience, failure to communicate, and lack of cooperation rendered the [d]epartment’s efforts sufficient”); see also Patricia H., 2002-NMCA-061, ¶¶ 23, 31 (explaining that the “level of cooperation” by the parent factors into the reasonableness of the department’s efforts); Vanessa C., 2000-NMCA-025, ¶ 29 (reasoning that under the totality of the circumstances the district court properly found that the evidentiary standard for termination was met when there was “two y

11
State Ex Rel. Children, Youth & Families Department v. Vanessa C.green
nmctapp · 2000 · cited in 1 New Mexico opinions naming this issue, 2020–2020
1 sentence

2020Children, Youth & Families Dep’t v. Tammy S., 1999-NMCA-009, ¶ 15 , 126 N.M. 664 , 974 P.2d 158 (holding that the “[f]ather’s transience, failure to communicate, and lack of cooperation rendered the [d]epartment’s efforts sufficient”); see also Patricia H., 2002-NMCA-061, ¶¶ 23, 31 (explaining that the “level of cooperation” by the parent factors into the reasonableness of the department’s efforts); Vanessa C., 2000-NMCA-025, ¶ 29 (reasoning that under the totality of the circumstances the district court properly found that the evidentiary standard for termination was met when there was “two y

11
Carzell Moore v. Ralph Kemp, Warden, Georgia Diagnostic and Classification Center, Respondentgreen
ca11 · 1987 · cited in 1 New Mexico opinions naming this issue, 2007–2007
2 sentences

2007See id. at 709-710 .

2007See id. at 709-710 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Mexico. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Santillo v. New Mexico Department of Public Safety green
nmctapp · 2007
2 sentences

2009Safety, 2007-NMCA-159, ¶ 17 , 143 N.M. 84 , 173 P.3d 6 ("The plain language of the statute is our primary guide to legislative intent[.]"). {9} Section 1914 explicitly permits a parent to challenge—in any court of competent jurisdiction—three types of violations: (1) Section 1911, which concerns tribal court jurisdiction; (2) Section 1912, which concerns the proof required to substantiate a termination of parental rights or a foster care placement; or (3) Section 1913, which concerns the validity of a parent's consent to termination or foster care placement.

2009Safety, 2007-NMCA-159, ¶ 17 , 143 N.M. 84 , 173 P.3d 6 ("The plain language of the statute is our primary guide to legislative intent[.]"). {9} Section 1914 explicitly permits a parent to challenge—in any court of competent jurisdiction—three types of violations: (1) Section 1911, which concerns tribal court jurisdiction; (2) Section 1912, which concerns the proof required to substantiate a termination of parental rights or a foster care placement; or (3) Section 1913, which concerns the validity of a parent's consent to termination or foster care placement.

22009–2009
Santillo v. NM Dept. of Public Safety green
nmctapp · 2007
2 sentences

2009Safety, 2007-NMCA-159, ¶ 17 , 143 N.M. 84 , 173 P.3d 6 (“The plain language of the statute is our primary guide to legislative intent[.]”). {9} Section 1914 explicitly permits a parent to challenge — in any court of competent jurisdiction — -three types of violations: (1) Section 1911, which concerns tribal court jurisdiction; (2) Section 1912, which concerns the proof required to substantiate a termination of parental rights or a foster care placement; or (3) Section 1913, which concerns the validity of a parent’s consent to termination or foster care placement.

2009Safety, 2007-NMCA-159, ¶ 17 , 143 N.M. 84 , 173 P.3d 6 ("The plain language of the statute is our primary guide to legislative intent[.]"). {9} Section 1914 explicitly permits a parent to challenge—in any court of competent jurisdiction—three types of violations: (1) Section 1911, which concerns tribal court jurisdiction; (2) Section 1912, which concerns the proof required to substantiate a termination of parental rights or a foster care placement; or (3) Section 1913, which concerns the validity of a parent's consent to termination or foster care placement.

22009–2009
State Ex Rel. Children, Youth & Families Department v. Tammy S. green
nmctapp · 1998
2 sentences

2020Children, Youth & Families Dep’t v. Tammy S., 1999-NMCA-009, ¶ 15 , 126 N.M. 664 , 974 P.2d 158 (holding that the “[f]ather’s transience, failure to communicate, and lack of cooperation rendered the [d]epartment’s efforts sufficient”); see also Patricia H., 2002-NMCA-061, ¶¶ 23, 31 (explaining that the “level of cooperation” by the parent factors into the reasonableness of the department’s efforts); Vanessa C., 2000-NMCA-025, ¶ 29 (reasoning that under the totality of the circumstances the district court properly found that the evidentiary standard for termination was met when there was “two y

2020Children, Youth & Families Dep’t v. Tammy S., 1999-NMCA-009, ¶ 15 , 126 N.M. 664 , 974 P.2d 158 (holding that the “[f]ather’s transience, failure to communicate, and lack of cooperation rendered the [d]epartment’s efforts sufficient”); see also Patricia H., 2002-NMCA-061, ¶¶ 23, 31 (explaining that the “level of cooperation” by the parent factors into the reasonableness of the department’s efforts); Vanessa C., 2000-NMCA-025, ¶ 29 (reasoning that under the totality of the circumstances the district court properly found that the evidentiary standard for termination was met when there was “two y

12020–2020
State Ex Rel. Children, Youth & Families Department v. Marlene C. green
nmctapp · 2009
2 sentences

2011Under 25 U.S.C. § 1914 (1978), a parent can challenge in any court of competent jurisdiction for violations of “Section 1912, which concerns the proof required to substantiate a termination of parental rights or a foster care placement.” Marlene C., 2009-NMCA-058, ¶ 9 , 146 N.M. 588 , 212 P.3d 1142 . {43} We hold there was sufficient evidence for the district court to find beyond a reasonable doubt that CYFD engaged in active efforts to provide remedial services and rehabilitative programs. {44} The district court made adequate findings, in its adopted findings of fact, that CYFD engaged in ac

2011Under 25 U.S.C. § 1914 (1978), a parent can challenge in any court of competent jurisdiction for violations of “Section 1912, which concerns the proof required to substantiate a termination of parental rights or a foster care placement.” Marlene C., 2009-NMCA-058, ¶ 9 , 146 N.M. 588 , 212 P.3d 1142 . {43} We hold there was sufficient evidence for the district court to find beyond a reasonable doubt that CYFD engaged in active efforts to provide remedial services and rehabilitative programs. {44} The district court made adequate findings, in its adopted findings of fact, that CYFD engaged in ac

12011–2011
State of Nm Ex Rel. Cyfd v. Marlene C. green
nmctapp · 2009
1 sentence

2011Under 25 U.S.C. § 1914 (1978), a parent can challenge in any court of competent jurisdiction for violations of “Section 1912, which concerns the proof required to substantiate a termination of parental rights or a foster care placement.” Marlene C., 2009-NMCA-058, ¶ 9 , 146 N.M. 588 , 212 P.3d 1142 . {43} We hold there was sufficient evidence for the district court to find beyond a reasonable doubt that CYFD engaged in active efforts to provide remedial services and rehabilitative programs. {44} The district court made adequate findings, in its adopted findings of fact, that CYFD engaged in ac

12011–2011
State v. Lefevre green
nmctapp · 2005
2 sentences

2008Parental Privilege {10} This Court recently held that "in New Mexico, a parent has a privilege to use moderate or reasonable physical force, without criminal liability, when engaged in the discipline of his or her child." State v. Lefevre, 2005-NMCA-101, ¶ 16 , 138 N.M. 174 , 117 P.3d 980 .

2008Parental Privilege {10} This Court recently held that "in New Mexico, a parent has a privilege to use moderate or reasonable physical force, without criminal liability, when engaged in the discipline of his or her child." State v. Lefevre, 2005-NMCA-101, ¶ 16 , 138 N.M. 174 , 117 P.3d 980 .

12008–2008

Statutes the citing opinions construe

NM § N.M. Stat. § 32A-4-28 (4) NM § N.M. Stat. § 32A-4-19 (3) NM § N.M. Stat. § 32A-4-2 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 84 (1915–2026) IA 67 (1955–2026) NY 53 (1899–2025) TX 31 (1903–2025) PA 24 (1943–2024) CO 22 (1990–2025) OH 12 (2007–2026) MO 12 (1913–2021) IL 11 (1909–2023) MN 11 (1985–2024) MI 11 (1981–2026) GA 9 (1941–2026) OR 9 (1987–2024) NM 8 (2007–2020) FL 8 (1981–2012) RI 8 (1983–2023) IN 8 (1978–2025) WY 7 (1883–2023) TN 7 (2008–2021) NE 7 (1976–2022) AL 5 (2008–2026) MD 5 (1971–2010) AZ 5 (1983–2024) NJ 4 (1976–2024) AK 4 (2007–2021) DC 4 (1997–2021) AR 4 (1970–2017) NC 4 (1988–2021) ME 4 (1986–2020) KY 4 (2009–2023) MA 4 (2003–2025) UT 3 (2017–2023) ID 3 (2020–2020) WI 3 (1985–2023) CT 3 (1988–2001) NV 2 (1993–2013) HI 2 (2007–2008) SC 2 (1993–2012) WV 2 (1917–2013) MT 2 (1927–2020) KS 2 (1992–1992) DE 2 (1960–2026) ND 2 (2005–2005) VA 2 (2022–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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