C.L.S. v. State, 345 P.3d 1281

T1 C.L.S. (Father) appeals a juvenile court order terminating his parental rights to KL.S.; the state superiorly affirms.
The court affirmed based on proven grounds under Utah Code § 78A-6-507 and best interests under § 78A-6-506(8).
Father was represented by counsel until Nov. 12, 2018, then proceeded pro se at termination proceedings; no claim of counsel error raised on appeal.
The court found KL.S. was neglected and Father was an unfit or incompetent parent, with out-of-home placement under DCFS supervision.
Findings also showed substantial failure to remedy circumstances, likelihood of future incapacity to provide proper care, and a supported best-interest determination in a suitable adoptive home.
The record supported reasonable DCFS efforts toward reunification and favorable best-interest findings for adoption.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of grounds for termination	Father argues the evidence is insufficient to support termination grounds.	State asserts the evidence supports one or more enumerated grounds under §78A-6-507.	Yes; the evidence supports termination on multiple grounds.
Counsel at termination trial	Father contends lack of counsel at termination trial.	Juvenile court found Father fully informed and choosing to represent himself.	No basis to review; findings support the pro se status.
Best interests support	State offered limited evidence beyond foster care love; questioned sufficiency for §78A-6-509(1)(a).	Factual findings show bond, safety, stability, and adoptive potential supporting best interests.	Findings adequately support the best-interest termination decision.

In re B.R., 171 P.3d 435 (Utah 2007) (clear weight of the evidence standard; not to reweigh evidence)
In re E.R., 21 P.3d 680 (Utah Ct. App. 2001) (clearly erroneous standard for factual findings)
State v. Blubaugh, 904 P.2d 688 (Utah Ct. App. 1995) (regularity presumed; transcript required for appeal challenges)