Manuel M. v. Arizona Department of Economic Security
In Manuel M. v. Arizona Department of Economic Security, 218 Ariz. 205, 181 P.3d 1126 (App. 2008) the Court concluded a "parent admits only the factual contentions contained in the termination motion" by failing to appear at a termination hearing and, thus, "a parent's failure to appear does not relieve the juvenile court of its obligation to assess the 'record and evidence' presented and to determine whether the state has proven a statutory ground for termination by clear and convincing evidence." 218 Ariz. 205, PP 23, 28, 181 P.3d at 1133, 1134.
The Court further concluded that "exhibits that had been duly admitted at prior dependency hearings were part of the record and thus properly considered by the court" at termination. Id. P 34.