In re M.M., 536 P.3d 102

Child experienced unexplained bruising in 2016; DCFS investigated, Child was adjudicated abused by an unknown perpetrator, and Mother completed services and regained custody in 2017.
In 2019 Mother’s youngest (Brother) suffered severe injuries (brain bleed, healing rib fractures); doctors concluded injuries were consistent with inflicted trauma while in Mother’s care.
State filed custody petitions for all three children; Mother entered a rule 34(e) plea in 2020 (neither admit nor deny; treated as admitted) and the court found Brother severely abused while in Mother’s care; Child and Sister were adjudicated siblings at risk/neglected.
Mother repeatedly violated a court-ordered safety plan; DCFS removed Child from Mother’s custody in January 2020 and placed Child in foster care.
The juvenile court denied reunification services to Mother (Sept. 2020), set adoption as the permanency goal (Apr. 2021), and after an eight-day bench trial (Mar–Apr. 2022) terminated Mother’s parental rights, finding statutory grounds by clear and convincing evidence and that termination was strictly necessary.
Mother appealed, arguing (1) the court erred in denying reunification services and (2) the court’s “strictly necessary” best-interest analysis was inadequate; the appellate court affirmed.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (State)	Held
Whether the juvenile court erred by denying reunification services	Court misapplied law, failed to make required findings for presumption against services, and improperly weighed statutory factors in Mother’s favor	Denial appropriate given Mother’s prior services, noncompliance with safety plan, history suggesting violent behavior and exposure of children to repeated abuse	Affirmed — no abuse of discretion; court considered statutory factors and denial was not against clear weight of evidence
Whether termination of parental rights was "strictly necessary"	Court’s strict-necessity analysis was too brief/conclusory and improperly relied on categorical preference for adoption over guardianship	Termination strictly necessary because no feasible alternative placements existed and Child had strong emotional ties to foster family	Affirmed — court reasonably found no feasible alternative and terminating rights was strictly necessary for Child’s best interest

In re S.T., 521 P.3d 887 (Utah Ct. App. 2022) (two-part termination test; termination only if strictly necessary to child’s best interest)
In re B.T.B., 472 P.3d 827 (Utah 2020) (best-interest/strict-necessity analysis requires exploration of feasible non-termination options)
In re J.A.L., 506 P.3d 606 (Utah 2022) (adoption’s permanency cannot be the sole categorical basis for denying alternatives)
In re E.R., 496 P.3d 58 (Utah 2021) (standard of review: deferential review of dispositional decisions; overturn if decision against clear weight of evidence)
In re D.G., 522 P.3d 39 (Utah Ct. App. 2022) (absence of apparent alternatives can support termination)
In re J.J.W., 520 P.3d 38 (Utah Ct. App. 2022) (deferential review of best-interest determinations)
In re Z.G., 376 P.3d 1077 (Utah Ct. App. 2016) (reunification services decision rests within juvenile court discretion)
In re A.K., 344 P.3d 1153 (Utah Ct. App. 2015) (parents have no constitutional right to reunification services)