Adoption of L.R.B and D.W.B., 2017 MT 172N

Father (J.B.) and Mother divorced in May 2010; two minor children are L.R.B. and D.W.B. Mother married Warren Reeves in July 2011 and the children have lived with Mother and Reeves since.
Father has had limited contact since the divorce (occasional Skype, rare visits) and owed about $11,000 in child support as of January 2017.
Reeves petitioned to terminate Father’s parental rights under §§ 42-2-607 and -608, MCA, and to adopt the children.
The Fifth Judicial District Court (Madison County) denied Reeves’ petition, finding Father derelict in support but concluding he had not abandoned the children.
Reeves appealed, arguing the district court failed to make the specific factual findings and conclusions required when deciding termination under §§ 42-2-607 and -608.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in denying petition to terminate parental rights	Reeves: Father failed to financially support children, is unwilling to maintain contact, poses risk, and termination is in children’s best interest	Father: (implicit) has not abandoned children; retains parental rights despite faults	Court: Yes—abuse of discretion because court failed to make required specific findings of fact and conclusions of law; reverse and remand for new hearing
Whether the district court made sufficient findings under §§ 42-2-607 and -608, MCA	Reeves: Court must make specific factual findings addressing best interests, contact willingness, risk of harm, detriment of denial	District Court: Reached ultimate denial but issued a brief order without detailed findings	Court: Order lacked required specific findings; remand for findings and new hearing

In re Adoption of A.W.S., 384 Mont. 278, 377 P.3d 1201 (2016) (standard of review for termination decisions)
In re J.W.M., 380 Mont. 282, 354 P.3d 626 (2015) (district courts must make specific factual findings when terminating parental rights)