Before Justices Douglas, Hardesty and Parraguirre. Opinion by Justice Douglas.
In this appeal from a judgment terminating parental rights, the Court reversed and remanded the district court’s decision terminating parental rights because the district court failed to state any factual or legal basis for the termination. The order, submitted by the state, recited the statutory bases for terminating parental rights but did not recite any facts from the two-day bench trial or apply the law to those facts. Citing the high standard of proof for termination proceedings and NRCP 52(a), which requires district courts to separately state its findings of fact and conclusions of law in a judgment on a bench trial, the Court held that it could not review the decision because neither the written order nor the record of oral proceedings contained factual findings. Reversed and remanded. (Kerry S. Doyle, Associate in the Reno office of McDonald Carano Wilson LLP).
