New Mexico Health and Social Services Department v. Smith

This appeal involves the termination of the parental right of the mother of a child, approximately 2 1/2 years old at the termination hearing. The mothers appeal raises issues as to the trial courts findings, which need not be discussed, either because the particular finding is supported by substantial evidence or because irrelevant to the decision. We discuss: (1) Evidence Rule 504, the psychotherapist-patient privilege, and (2) requirements for termination of the mothers parental right.