L.K. v. State, 397 P.3d 745

Father appealed termination of his parental rights; juvenile court terminated based on grounds including unfitness.
Juvenile court found Father had extensive history of substance abuse (completed one program, later overdosed in suicide attempt, later tested positive for methamphetamine and marijuana).
Court found Father had unresolved domestic violence issues; he had begun but not completed domestic violence classes at time of trial.
Father maintained an ongoing, volatile relationship with the mother, who had relinquished her parental rights and had unresolved drug and mental-health issues; Father minimized those risks and intended to remain with her.
DCFS provided multiple reunification services (evaluations, referrals, financial help, shelter placement), but Father failed to consistently engage or sustain sobriety and left shelter early.
Father did not preserve an objection to the mother’s testimony on spousal-privilege grounds at trial, so appellate review declined on that issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sufficient evidence supported termination (unfitness)	Father argued insufficient evidence of unfitness	Juvenile court found drug relapse, suicide attempt, ongoing substance abuse, incomplete domestic-violence treatment, and risky relationship with mother	Affirmed: evidence supports finding of unfitness; any single ground suffices for termination
Whether DCFS made reasonable reunification efforts	Father argued DCFS failed to make reasonable efforts	State showed extensive services, referrals, financial support, and coordination; Father did not fully utilize services	Affirmed: DCFS made reasonable efforts; reunification requires parent participation
Whether mother could invoke spousal privilege to block her testimony	Father contended court improperly applied privilege broadly	Court ruled privilege inapplicable under Utah R. Evid. 502(e)(4) because child’s interests could be adversely affected; Father did not object to specific testimony at trial	Not reviewed on appeal: issue not preserved by timely specific objections
Best-interest determination	Father did not challenge the best-interest ruling	N/A	Not addressed on appeal (undisputed/not challenged)

In re B.R., 171 P.3d 435 (Utah 2007) (appellate standard and deference to juvenile court findings)
In re E.R., 21 P.3d 680 (Utah Ct. App. 2001) (clearly erroneous standard for factual findings)
In re A.C., 97 P.3d 706 (Utah Ct. App. 2004) (reasonable efforts defined for reunification)
In re P.H., 783 P.2d 565 (Utah Ct. App. 1989) (reunification is reciprocal: services and parental commitment required)
In re K.F., 201 P.3d 985 (Utah 2009) (reasonableness of reunification efforts is fact-specific)
Brookside Mobile Home Park, Ltd. v. Peebles, 48 P.3d 968 (Utah 2002) (preservation of issues for appeal requires timely presentation to trial court)
In re F.C. III, 81 P.3d 790 (Utah Ct. App. 2003) (any single statutory ground supports termination of parental rights)