Valencia v. Duval Corp‪.‬

In this appeal from the trial courts November 13, 1981 order severing appellants parental rights over her three daughters, appellant presents four arguments. First, the evidence was insufficient to support the trial courts findings in support of severance; second, the trial court erred in terminating appellants parental rights without a showing of why dependency proceedings would be inadequate to protect the children; third, Arizonas termination statutes are unconstitutional because they fail to take into account, or to include as factors, the constitutionally protected rights of the stepfather and the family unit; and, fourth, the termination was void because Arizonas termination statutes have been rendered unconstitutional by the recent United States Supreme Court decision of Santosky v. Kramer, 450 U.S. 993, 102 S.Ct. 1388, 71 L.Ed.2d 599 (1982).