Lisa K. v. Arizona Department of Economic Security, 230 Ariz. 173

Lisa K. appeals from a juvenile court order terminating her parental rights to Julian N. based on mental illness or chronic substance abuse and length of time in court-ordered care.
ADES removed Julian in November 2009 when he was four months old due to domestic violence reports.
The juvenile court adjudicated Julian dependent in February 2010 and set a reunification goal.
In 2011 the court changed the case-plan goal to severance and adoption after hearings.
ADES filed a motion to terminate within ten days, and Lisa challenged § 8-862 as unconstitutional; the court affirmed the termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is § 8-862 facially unconstitutional?	Lisa argues the statute allows the same judge to order termination and preside over the hearing.	ADES argues the statute is constitutional and provides procedural safeguards.	No; § 8-862 is not facially unconstitutional.
Does Lisa have standing to challenge the constitutionality of § 8-862?	Lisa contends she has standing to challenge the statute.	ADES concedes she has standing for this challenge.	Lisa has standing to raise the constitutional challenge.
Did the statutory process violate due process or lead to an impartial tribunal?	Lisa asserts the process undermines impartiality.	The system provides procedural protections and the same judge handling related steps does not violate due process.	The process provides adequate safeguards; no due process violation shown.

Kent K. v. Bobby M., 210 Ariz. 279 (2005) (establishes balance of burdens and best-interests standard in juvenile termination)
Mara M. v. Ariz. Dep’t of Econ. Sec., 201 Ariz. 503 (Ariz. 2002) (due process and parental rights termination framework)
Rita J. v. Ariz. Dep’t of Econ. Sec., 196 Ariz. 512 (Ariz. 2000) (one-family/one-judge model and expedited permanency considerations)
Withrow v. Larkin, 421 U.S. 35 (1975) (conceptual support for non-impaired adjudicative process)