In re K.W., 45 Kan. App. 2d 353

Mother D.W. appeals a district court termination of parental rights involving four children: K.W., J.W., K.W., and C.W.
Mother contends the district court violated her constitutional right to parent and failed to meet the evidentiary standard for termination.
The district court did not expressly reflect that all statutory findings were made and that the proper standard of proof was used, according to the court’s review standards.
Appellate review requires a determination that clear and convincing evidence supports termination when rights are at stake.
The court found a best interests determination was not made, which prevents meaningful appellate review of the termination order.
This court vacates the judgment and remands with directions to make the required statutory findings and best-interests determination, expediting proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court complied with statutory findings for termination.	Mother argues findings were not properly made.	State contends evidence supports termination under the statute.	Vacated and remanded for proper findings

In re B.E.Y., 40 Kan. App. 2d 842, 196 P.3d 439 (2008) (requires expressly reflecting all statutorily mandated findings and proper standard of proof)
In re B.D.-Y., 286 Kan. 686, 187 P.3d 594 (2008) (clarifies that clear and convincing evidence applies in termination and rights-at-stake cases)