In the Interest Of: MC, HC and CC, Minor Children, DL v. State of Wyoming, Department of Family Services, 2013 WY 43

DL was adjudicated to have neglected her three children MC, HC, and CC; petition filed Jan 27, 2012 in Hot Springs County.
CC, age 12, claimed to be 'baked' at school; police obtained a search warrant, marijuana found, DL arrested for possession.
Shelter care hearing held; stipulation required DL to clean home, return children, and allow DFS inspections with random drug testing; children returned under conditions.
Adjudicatory hearing set for Apr 23, 2012; DL moved to dismiss or strike for discovery violations (negative UA for CC not provided; no witness list).
County attorney disclosed CC’s negative UA the Friday before the hearing; GAL and DFS provided information; DL’s counsel argued discovery issues.
Adjudicatory hearing proceeded; court found neglect; disposition returned some children to DL under DFS oversight; appellant appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court abuse discretion on the discovery ruling	DL argues denial of due process due to late exculpatory info and no witness list.	State contends discovery remedies were within court discretion and no prejudice shown.	No abuse; due process satisfied; remedies adequate.
Was there sufficient evidence of neglect	DL claims home conditions and marijuana use do not prove neglect.	State argues evidence shows unhealthy environment and nexus to neglect.	Yes, sufficient evidence to support neglect finding.

In re MM, 202 P.3d 409 (Wy. 2009) (juvenile discovery standard; abuse/neglect context)
In re KMO, 280 P.3d 1216 (Wy. 2012) (due process in juvenile proceedings; standard of review for discovery)
In re DRS, 261 P.3d 697 (Wy. 2011) (defer to trial court on findings; standard of review for sufficiency)
"H" Children, 79 P.3d 997 (Wy. 2003) (fundamental due process in child abuse/neglect; notice and hearing standards)
In re MLM, 682 P.2d 982 (Wy. 1984) (child welfare environment and swift state action standards)
Davis v. State, 47 P.3d 981 (Wy. 2002) ( Brady-like considerations in juvenile context; cross-examination focus)