Reed v. State (In re AM-LR), 421 P.3d 551

Mother (Chelsea Reed) admitted to juvenile neglect regarding two children after unsafe home conditions; children placed in DFS custody and a reunification plan was initially adopted.
MDT repeatedly warned reunification would be discontinued if Mother failed to make progress; Mother did not substantially comply.
Juvenile court changed the permanency goal to adoption and entered an Order Upon Permanency Hearing (July 21, 2016) terminating reunification efforts; Mother did not appeal that order.
DFS filed a separate district-court petition to terminate parental rights; after a bench trial the district court terminated Mother’s rights (July 26, 2017) on statutory grounds including thirty months in foster care and risk to children’s health/safety.
Mother appealed only alleging due process violations in the juvenile permanency proceedings (lack of notice of the hearing’s changed nature and right to request an evidentiary hearing), effectively attempting a collateral attack on the juvenile permanency order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May Mother collaterally attack the juvenile court’s permanency order via appeal of the district court termination order?	Mother: Juvenile court violated due process by failing to give notice of the permanency hearing change and her right to request an evidentiary hearing; this error infects the termination.	State/DFS: Juvenile permanency order was a final, appealable judgment; Mother failed to appeal that juvenile order and did not challenge juvenile court jurisdiction, so collateral attack is improper.	Court: Denied collateral attack; Mother must have challenged the juvenile order directly; no jurisdictional defect shown, so termination affirmed.

In re Adoption of SSO, 406 P.3d 723 (Wyo. 2017) (collateral attack on a juvenile judgment is generally disallowed unless the juvenile court lacked jurisdiction)
In re Estate & Guardianship of Andrews, 39 P.3d 1021 (Wyo. 2002) (standards for reviewing collateral-attack jurisdictional issues)
In re MN v. State, 78 P.3d 232 (Wyo. 2003) (neglect and termination proceedings are separate; errors in juvenile proceedings may be harmless in termination proceedings)
AA v. Wyo. Dep’t of Family Servs. (In re HP), 93 P.3d 982 (Wyo. 2004) (juvenile order ceasing reunification affects substantial rights and is appealable)
KC v. State (In the Interest of GC), 351 P.3d 236 (Wyo. 2015) (juvenile orders affecting substantial rights are appealable)
In re KGS v. State, 386 P.3d 1144 (Wyo. 2017) (parent must raise errors in juvenile proceedings; representation and full participation in termination proceedings weigh against finding due process violation)
Moore v. State, 215 P.3d 271 (Wyo. 2009) (final judgments ordinarily must be challenged by direct appeal)
Osborn v. Painter, 909 P.2d 960 (Wyo. 1996) (principles limiting collateral attacks on judgments)
Interest of K.R.T., 505 S.W.3d 864 (Mo. Ct. App. 2016) (a judgment is generally susceptible only to direct appeal unless void for lack of jurisdiction)
In Interest of NP, 389 P.3d 787 (Wyo. 2017) (applicability of civil procedure rules to juvenile proceedings and characterization of juvenile orders as judgments)