In re J.H and K.H. (R.O. and T.O. v. E.O.), 2012 UT App 195

E.O. appeals a juvenile court order granting permanent guardianship to the maternal grandparents.
The juvenile court found that E.O. neglected J.H. and K.H. based on extended absence, drug/alcohol abuse, homelessness, and incarceration.
The court noted an episode where E.O. left an older child unattended to care for younger children.
The court found E.O. discussed the legal proceedings with the children contrary to a court order, contributing to neglect.
The evidence support for neglect included the totality of E.O.'s behavior and the violation of court orders.
The court admitted the maternal grandfather’s journal as an exhibit, over E.O.’s objection, to aid its findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether neglect findings are supported by the evidence	E.O. contends insufficient evidence of neglect.	R.O. and T.O. argue the record supports neglect.	Neglect findings supported; affirmed.
Whether admission of the grandfather's journal was error	E.O. argues rule 803(5) violation prejudiced outcome.	Grandparents contend error was harmless and supported by independent evidence.	Admission not reversible; no likely impact on outcome; affirmed.

In re B.R., 171 P.3d 435 (Utah 2007) (clearly erroneous standard for review of factual findings in juvenile cases)
In re L.M., 37 P.3d 1188 (Utah 2001) (juvenile court credibility and factual findings given deference)
In re E.R., 21 P.3d 680 (Utah 2001) (standard for reviewing juvenile court findings of fact)
State v. Otterson, 184 P.3d 604 (Utah App. 2008) (harmless error standard in evidentiary rulings)