In re M.V., 808 N.W.2d 916

One-month-old child suffered severe injuries consistent with non-accidental trauma; state filed abuse/neglect petition.
Father was primary caregiver while Mother worked; medical experts diagnosed non-accidental trauma.
Child adjudicated abused or neglected; State supervised custody, then child returned to Mother and case dismissed as to Mother.
Mother appealed challenging separate culpability findings and the sufficiency of the abuse/neglect finding.
Circuit court found abuse/neglect under SDCL 26-8A-2(1) and (3), no separate Mother/Father culpability findings required.
Mother sought removal from central registry; appeal affirmed; registry action administrative and not within juvenile court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must court make separate culpability findings for Mother and Father?	Mother argues required by SDCL 15-6-56; need separate findings.	Child status adjudication suffices; separate fault findings not necessary.	No; separate culpability findings not required to adjudicate status.
Was the Child's abuse/neglect finding clearly erroneous?	Mother claims injuries could be from others or treatment.	Evidence supported non-accidental trauma by multiple doctors.	No clear error; findings supported by medical testimony and chronology.
Did the court err by not adopting SDCL 26-8A-2(5) alternative?	Alternative basis should be considered.	Sufficiency under subsections (1) and (3) already established.	Not required; substantial basis found under (1) and (3).

DeHaven v. Hall, 2008 S.D. 57 (S.D. 2008) (findings on disputed factual issues; materiality governs necessity)
Fin-Ag, Inc. v. Pipestone Livestock Auction Mkt, Inc., 2008 S.D. 48 (S.D. 2008) (materiality of facts; not all disputes require findings)
Davies v. Toms, 75 S.D. 273, 63 N.W.2d 406 (S.D. 1954) (findings must address only issues necessary to action)
In re S.L., 419 N.W.2d 689 (S.D. 1988) (any one statute subsection can sustain adjudication)