Mariah B. v. State of Alaska, DHSS, OCS, 499 P.3d 1021

OCS petitioned to terminate Mariah B.’s parental rights under AS 47.10.011 (abandonment, neglect, parental substance abuse); a multi-day termination trial occurred in early 2021.
The State’s primary witnesses included the child’s foster mother and an OCS supervisor who relied heavily on OCS report-of-contact (ROC) notes and undocumented conversations with caseworkers.
The mother objected before and during the supervisor’s testimony to hearsay based on ROC notes and informal caseworker statements and sought to exclude ROC notes as business records.
The superior court twice said it would "deem" the supervisor’s testimony admissible (while reserving the right to change its mind) and told the mother she was "not waiving" her objections; the court nevertheless allowed the supervisor to testify without further contemporaneous objections.
OCS ultimately did not introduce the ROC notes, but admitted other records (case plans, treatment records, urinalysis results, CTC reviews); the superior court relied on the supervisor’s testimony, calling her "very credible," but never explained any evidentiary ruling or how hearsay influenced its findings.
The Supreme Court held the mother preserved her objections but remanded because the superior court failed to articulate the bases and limits (if any) of its hearsay ruling under CINA Rule 18(f), leaving the record "essentially unreviewable."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mother preserved hearsay objections to the supervisor’s testimony	Mother: her standing/blanket objections and the court’s rulings preserved the issue for appeal	OCS: mother should have objected to each hearsay-dependent question because the court’s rulings were preliminary	Court: preserved — the court definitively admitted the testimony (while reserving right to change), and did not instruct repeated contemporaneous objections; mother’s objections were preserved
Whether the appellate record suffices to review admission/use of hearsay under CINA Rule 18(f)	Mother: court failed to explain its admissibility ruling or how it relied on hearsay; remand required	OCS: supervisor’s testimony plausibly admissible under Rule 18(f) or as non-hearsay background; record adequate	Court: remand — trial court did not state the purpose(s) for admission, the bases for finding "circumstantial guarantees of trustworthiness," or how hearsay affected findings; record is inadequate for review

Jeff A.C., Jr. v. State, 117 P.3d 697 (Alaska 2005) (discussing CINA Rule 18(f) two-tiered hearsay standard)
Wassillie v. State, 411 P.3d 595 (Alaska 2018) (business/incident reports may lack assured neutrality and thus fail Rule 803(6))
Torres v. State, 519 P.2d 788 (Alaska 1974) (contemporaneous-objection/preservation principles)
In re A.S.W., 834 P.2d 801 (Alaska 1992) (affirming admission under residual hearsay exception after trial court made specific reliability findings)
Broderick v. King’s Way Assembly of God Church, 808 P.2d 1211 (Alaska 1991) (appellate review requires indication of factors considered by trial court)
Bird v. Starkey, 914 P.2d 1246 (Alaska 1996) (remand required where trial court’s reasons are not apparent and decision is essentially unreviewable)
Diego K. v. State, 411 P.3d 622 (Alaska 2018) (noting heightened care required in proceedings that terminate parental rights)