In the Matter of JH, 2016 MT 35 (Feb. 16, 2016) (Rice, J.) (5-0, aff’d)
Issue: (1) Whether the district court erred by finding the Department made reasonable efforts to reunify JH with his father; (2) whether the district court erred by finding that JH’s best interests were served by living with his aunt, EJ, and not his father; and (3) whether the district court erred by approving a permanency plan without first holding an age-appropriate consultation with JH.
Short Answer: (1) No; (2) no; and (3) no.
Facts: JH, seven years old, is the child of AH (mother) and CL (father). Mother and father never married, no custody order or parenting plan was ever entered, and JH saw his father only occasionally.…