Interest of C.A.S., 993 N.W.2d 347

J.D. (mother) and C.S. (father) are parties in consolidated juvenile proceedings involving seven children; C.S. is father of three children; other fathers did not appear.
At the termination trial, C.S. attended but J.D. did not; J.D.’s counsel requested she be allowed to appear electronically or that the trial be continued; the court denied both requests.
The petitioner (Grand Forks County Human Service Zone) presented testimony from a child protection supervisor and the children’s foster care case manager supporting termination; J.D.’s adult daughter also testified for J.D.; C.S. did not testify or call witnesses.
The juvenile court entered an order terminating parental rights of the parents; both J.D. and C.S. appealed; J.D. filed her appeal late and sought an extension of the appeal deadline.
The Supreme Court dismissed J.D.’s appeal for lack of jurisdiction as untimely under the expedited-appeal rule and summarily affirmed the termination as to C.S., concluding the findings were supported by clear and convincing evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether J.D. was denied due process by being absent at trial / whether her appeal was timely	J.D.: Appealed based on Rule 4(a)(1) (time runs from service of notice); sought electronic appearance or continuance; argued harmless error and asked for extension	State/Respondent: Appeal is governed by expedited Rule 2.2(a) (30-day deadline); Rule 4 does not apply; no rule-authorized extension; harmless-error exception not applicable to jurisdiction	Appeal untimely; no jurisdiction to hear it; extension denied; appeal dismissed
Whether termination of C.S.’s parental rights was supported by evidence	C.S.: Court erred in finding children in need of protection and that conditions will likely continue	State/Respondent: Record contains clear and convincing evidence supporting the juvenile court’s findings	Findings not clearly erroneous; termination as to C.S. summarily affirmed

Interest of A.S.F., 965 N.W.2d 870 (N.D. 2021) (untimely appeals in termination cases divest this Court of jurisdiction)
In re T.S.C., 908 N.W.2d 754 (N.D. 2018) (Rule 2.2, not Rule 4, governs timing for termination-of-parental-rights appeals)
Interest of A.C., 975 N.W.2d 567 (N.D. 2022) (review standard: clearly erroneous for factual findings in termination proceedings)
Interest of Guardianship of J.O., 958 N.W.2d 149 (N.D. 2021) (issues inadequately briefed when no supporting authority is cited)