Champagne v. Welfare Division

In Champagne v. Welfare Division, 100 Nev. 640, 691 P.2d 849 (1984) the Court interpreted the Nevada's termination statute and announced a two-step analysis to be applied when deciding whether to terminate parental rights. According to Champagne, the first step in the analysis requires that there be what the court characterized as "jurisdictional" grounds for termination. Id. at 640, 691 P.2d at 849. Jurisdictional grounds relate to "parental conduct or incapacity and the parent's suitability as a parent." Id. at 646, 691 P.2d at 854. In other words, jurisdictional grounds focus on parental fault or inability to act as a parent. If jurisdictional grounds for termination are not established, the inquiry ends. Id. at 647, 691 P.2d at 854. If jurisdictional grounds are established, the analysis turns to whether dispositional grounds exist for termination. Dispositional grounds relate to whether "the child's interest would be served by termination." Id. at 652, 691 P.2d at 857. The Champagne court explained that "if under no reasonable circumstances the child's best interest can be served by sustaining the parental tie, dispositional grounds for termination exist." Id. at 652, 691 P.2d at 858.