In re J. L. G., 924 N.W.2d 9

Grandmother (R.S.) sought to adopt her three grandchildren after parents' parental rights were terminated; county identified a foster family and executed an adoption-placement agreement without notifying grandmother.
County had interviewed grandmother in 2016–2017, concluded she was not appropriate due to inability to set boundaries with the mother, and informed her she had been "ruled out" as a placement.
A private agency (Wellspring) completed a home-study in 2018 with a qualified favorable recommendation, noting concerns about grandmother's relationship with the mother and need for supports.
The district court’s TPR order contained a factual finding that grandmother had been unable to protect the children from exposure to domestic abuse and drug use, but did not include an express court ruling excluding her as a placement.
Grandmother was not given statutorily required notice of the adoption-review hearing because the county and later the district court treated her as previously "ruled out;" she moved for adoptive placement but the court denied an evidentiary hearing for lack of a prima facie showing.
The appellate court reversed and remanded, holding the court must expressly rule out a relative before treating them as "ruled out," and remanded to reconsider whether grandmother made a prima facie showing of the county's unreasonableness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a relative is "ruled out by the court" for notice purposes only by an express court ruling	Grandmother: statute requires an express court ruling excluding a relative; factual findings in TPR are insufficient	County: TPR findings implicitly ruled grandmother out; no separate order necessary	Court: "ruled out by the court" requires an explicit court ruling; implicit findings are insufficient (reversed)
Whether grandmother made a prima facie showing that the county was unreasonable in not placing the children with her, entitling her to an evidentiary hearing	Grandmother: her affidavit and home study establish a prima facie showing; court should have held an evidentiary hearing	County: decision not to place was reasonable given concerns and prior determination grandmother was ineligible	Court: District court erred by denying a hearing based on its incorrect "ruled out" conclusion; remanded for the court to exercise discretion and reassess prima facie showing

Lee v. Lee, 775 N.W.2d 631 (de novo review of statutory interpretation)
State v. Jones, 848 N.W.2d 528 (statutory interpretation to discern legislative intent)
Am. Family Ins. Grp. v. Schroedl, 616 N.W.2d 273 (plain-language statutory analysis)
State v. Fleck, 810 N.W.2d 303 (ambiguity and multiple reasonable interpretations)
Larson v. State, 790 N.W.2d 700 (apply plain meaning when statute unambiguous)
Interstate Power Co. v. Nobles Cty. Bd. of Comm'rs, 617 N.W.2d 566 (appellate courts apply law as it exists when ruling)
In re Welfare of Children of L.L.P., 836 N.W.2d 563 (standards for review of dismissal without evidentiary hearing)
In re Welfare of M.F., 473 N.W.2d 367 (remand when district court addresses discretionary matters based on erroneous legal conclusions)