LeBlanc v. State, Department of Family Services, 401 P.3d 932

Mother had a long history with DFS and substance-abuse related criminal convictions; drugs and paraphernalia were found in her home in 2010 with children present, initiating neglect proceedings.
Multiple incidents followed: inadequate supervision, exposure of children to drugs and pornography, driving under the influence with children, and admissions to distributing methamphetamine; children were repeatedly removed and placed in alternate care.
ARLeB exhibited significant behavioral and mental-health issues (firesetting, lying, ADHD, PTSD, history of reported abuse); he spent time in residential treatment. RCW, Jr. showed adjustment disorder linked to mother’s drug use.
Mother completed some treatment, schooling, and had periods of reunification, but repeatedly relapsed into drug use and resumed unsafe living arrangements and associations after release from incarceration.
DFS petitioned to terminate parental rights in 2015 under multiple statutory grounds; bench trial occurred in 2016. The court closed the trial to the public to protect confidentiality of juvenile records and later terminated mother’s parental rights to both boys.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clear and convincing evidence supports termination under § 14‑2‑309(a)(v) (15 of 22 months in foster care + parent unfit)	DFS: children were in foster care for statutory period and mother is unfit due to ongoing substance abuse, criminality, unstable housing, unsafe associates, and contribution to children’s mental/behavioral problems	Mother: evidence insufficient to show current unfitness to have custody/control	Held: Affirmed — clear and convincing evidence supported termination under § 14‑2‑309(a)(v)
Whether closing the termination trial to the public violated the constitutional presumption of open courts	DFS/court: closure necessary to protect confidentiality of juvenile abuse/neglect records admitted at trial	Mother: closure violated Article I, § 8 (courts shall be open); no statutory authority to close termination trials generally	Held: Trial closure was erroneous (not narrowly tailored / no compelling need shown) but error was harmless because mother failed to show prejudice; termination affirmed

In re KGS, 386 P.3d 1144 (Wyo. 2017) (standard for reviewing sufficiency of evidence in parental‑rights termination; clear and convincing burden)
In re HLL, 372 P.3d 185 (Wyo. 2016) (fitness measured at time of termination; past conduct relevant)
Matter of GP, 679 P.2d 976 (Wyo. 1984) (fitness includes capacity to maintain a nurturing parent‑child relationship)
In re AGS, 337 P.3d 470 (Wyo. 2014) (multiple statutory grounds; need only uphold one supported by evidence)
State ex rel Feeney v. Dist. Court of 7th Judicial Dist., 607 P.2d 1259 (Wyo. 1980) (trial‑closure decision is within district court discretion)
Williams v. Stafford, 589 P.2d 322 (Wyo. 1979) (public access to proceedings protects confidence in judicial process; restrictions require compelling reasons)
Circuit Court of the Eighth Judicial Dist. v. Lee Newspapers, 332 P.3d 523 (Wyo. 2014) (limitations on public access must be narrowly tailored to a compelling interest)