In Re Ht, 276 P.3d 1054

Appellants Christopher and Huyen Cleveland appeal trial orders terminating parental rights to H.T. due to failure to correct prior deprived conditions.
H.T. had four older siblings (T.T., M.T., C.C., T.C.) previously adjudicated deprived and married parents’ rights terminated for them.
The 2006 termination related to the four older children was based on failure to correct conditions; the 2009 case sought deprived status/termination for H.T.
Evidence showed lack of counseling, anger management, parenting classes, and other DHS-recommended training not completed by either parent.
Mother repeatedly denied ongoing issues like domestic violence and failed to acknowledge abuse by Father; Father minimized injuries and did not complete required programs.
Trial court found clear and convincing evidence that the conditions leading to deprivation of the older children persisted and that termination was in H.T.’s best interests; both parents’ rights were terminated and H.T. was deprived; orders were affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was sufficient clear and convincing evidence to deprive H.T. and terminate.	Cleveland (Mother) argues insufficiency of evidence.	State contends conditions not corrected and deprivation proven.	Yes; clear and convincing evidence supported deprivation and termination.
Whether the trial court erred in severing jury trials from Father's proceedings.	Mother asserts error from lack of severance.	Court did not err; civil proceeding not requiring severance.	No reversible error; no basis shown for relief.
Commentary on Fifth Amendment refusals during trial violating due process.	Mother/Father claim improper comment on Fifth Amendment silence.	Such comment permissible in civil proceedings.	No reversible error; comments did not undermine fairness.
Whether the State should have provided pretrial transcripts at its expense.	Father sought full pretrial transcripts.	Court provided witness transcripts; no prejudice shown.	No error; lack of full transcripts not prejudicial.
Whether reading prior trial transcripts of children violated Sixth Amendment confrontation rights.	Father argues use of prior testimony violates Sixth Amendment.	Sixth Amendment does not apply to civil deprivation proceedings; prior trials allowed.	No Sixth Amendment violation; permissible under civil context.

In re S.B.C., 64 P.3d 1080 (Okla. 2002) (clear and convincing evidence standard for termination)
In re R.J.W., 789 P.2d 233 (Okla. 1990) (proves deprivation without requiring new abuse for each child)
In re C.C., 907 P.2d 241 (Okla. Civ. App. 1995) (civil deprivation proceeding guidance on admissibility of statements)
Miles v. State, 268 P.2d 290 (Okla. Crim. 1954) (confrontation rights in civil context; prior opportunity to cross-examine)
In re K.N.L., 154 P.3d 1276 (Okla. Civ. App. 2007) (Sixth Amendment rights not applicable to civil deprivation proceedings)
Barber v. Page, 390 U.S. 719 (U.S. 1968) (comment on privilege against self-incrimination in civil cases)