court of appeals decision (1-judge; not for publication)
TPR – Closing Argument
County’s closing argument exhorting jury to consider that gal “represents the child and what’s best for the child” merely described “how the parties and their attorneys were aligned,” not that jury “should consider the ‘best interest’ of the child.”
TPR – Evidence
Evidence that Amber voluntarily terminated her rights to her firstborn child was probative of “the fact to be proven, namely, the risk that Amber would neglect Cecilia.” Because … well, you’ll have to take the court’s word for it. It’s apparently self-evident that if you’ve terminated once, you’re more likely than not to neglect the next born. Nor was this evidence inflammatory and therefore unduly prejudicial.
