Interest of M.R., 2022 ND 68

North Star Human Service Zone petitioned for M.R. (a juvenile) to be adjudicated a "deprived child" and placed in North Star’s care until age eighteen.
The juvenile court found M.R. deprived, that remaining in the parental home was contrary to M.R.’s welfare, reasonable efforts were made to avoid removal, and placed M.R. with North Star; the order expired on M.R.’s eighteenth birthday.
Father J.R. appealed the deprivation and placement order; after the notice of appeal was filed, M.R. turned eighteen.
The parties were directed to brief whether the appeal was moot; father argued the deprivation finding could have collateral consequences (future child-custody proceedings, employment, housing, professional licensure).
The court found the father’s asserted collateral consequences were speculative, noted the father’s unrelated convictions and incarceration already produce substantial adverse effects, and concluded the order had expired and produced no demonstrated collateral consequences.
The Supreme Court dismissed the appeal as moot; Justice Crothers specially concurred, agreeing dismissal was proper and explaining the burden for invoking the collateral-consequences exception.

Issue	State's Argument	Father's Argument	Held
Mootness of juvenile order after child reached 18	Order expired with M.R.’s 18th birthday; appeal is moot absent collateral consequences	Not moot: deprivation finding may have collateral consequences affecting future proceedings and opportunities	Dismissed as moot — order expired and no shown collateral consequences
Applicability & proof for collateral-consequences exception	Father must show more than mere speculation; no evidence of actual or reasonably probable consequences here	Deprivation finding could be used in future deprivation determinations and affect employment/housing/licensure	Father’s allegations were speculative and insufficient to invoke exception
Effect of father’s criminal convictions/incarceration on collateral-consequences analysis	Any harms from deprivation finding are not greater than harms already flowing from father’s convictions/incarceration	Father contended deprivation finding itself could create separate harms	Court held that even if collateral harms existed, they would not be different or greater than consequences from his convictions; thus no live controversy

Interest of B.A.C., 902 N.W.2d 767 (N.D. 2017) (collateral-consequences exception applied where adjudication produced lasting federal firearms restriction)
In re G.K.S., 809 N.W.2d 335 (N.D. 2012) (no actual controversy when events make relief impossible)
Millang v. Hahn, 582 N.W.2d 665 (N.D. 1998) (discussing collateral-consequences test)
In re B.B., 746 N.W.2d 411 (N.D. 2008) (prior incidents may be considered in future deprivation determinations)
Carafas v. LaVallee, 391 U.S. 234 (U.S. 1968) (recognizing collateral legal consequences of a criminal conviction)
Putman v. Kennedy, 900 A.2d 1256 (Conn. 2006) (articulating burden: reasonable possibility of prejudicial collateral consequences required to avoid mootness)